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.
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.
Use of Appropriate National Correct Coding Initiative (NCCI) Edit Files Not Verified(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS did not verify its third-party contractor?s use of appropriate National Correct Coding Initiative (NCCI) edit files. 2 CFR 200.303 states that non-federal entities must ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity is managing [the program] in compliance with?terms and conditions of the federal award.? DHHS is required to use the most recent quarterly Medicaid NCCI edit files to ensure the proper payment of claims and to verify the correct edit files are used in processing claims. While DOH downloaded and sent the correct files to the third-party, it did not independently verify the third-party?s use of the updated edit files during the fiscal year. Because DHHS did not verify the use of the correct edit files, inaccurate, incomplete, or false claims could be paid.Recommendation:We recommend DHHS establish a system of regularly checking its third-party?s NCCI edits to ensure the correct edit files are used.DHHS?s Response and Corrective Action Plan:The Department concurs with this recommendation. The Division successfully created and tested a comparison file. The division will continue to work to resolve audit concerns. Implementation in production is set for November 2022.
Sufficiently-Detailed PIC Meeting Minutes Not Maintained(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS?s Program Integrity Committee (PIC) did not have well-documented meeting minutes showing the Office of Inspector General (OIG) reporting on utilization, fraud, waste, abuse, and recovery of Medicaid funds. 2 CFR 200.303 states that non-federal entities must ?establish and maintain effective internal control? that provides reasonable assurance that the non-federal entity is managing [the program] in compliance with? terms and conditions of the federal award.? PIC meetings were established so DHHS and OIG would meet monthly and report on utilization, fraud, waste, abuse, and recovery of Medicaid funds. However, it was recorded in only one of the seven monthly PIC meeting minutes that OIG reported on the required items. Staff turnover led to poorly recorded meeting minutes, which can result in incomplete, inaccurate, or untimely reporting of Medicaid funds abuse.Recommendation:We recommend that DHHS maintain detailed meeting minutes for its PIC meetings.DHHS?s Response:The Department concurs with this recommendation. The MOU between OIG and DIH/Medicaid and the PIC bylaws define that meeting minutes will be taken with each PIC Committee. These meeting minutes will be reviewed at the following PIC Committee meeting and voted on for approval.PIC bylaws specifically state:?To keep written minutes of all Committee meetings, with assistance of staff, including:? Date, time, and place of meeting;? Names of members present, absent, and excused;? Substance of all matters proposed, discussed or decided and a record of votes taken;? Names of all other individuals who appeared and the substance in brief of their testimony;? Any other information that any member requests to be entered in the minutes.?
Use of Appropriate National Correct Coding Initiative (NCCI) Edit Files Not Verified(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS did not verify its third-party contractor?s use of appropriate National Correct Coding Initiative (NCCI) edit files. 2 CFR 200.303 states that non-federal entities must ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity is managing [the program] in compliance with?terms and conditions of the federal award.? DHHS is required to use the most recent quarterly Medicaid NCCI edit files to ensure the proper payment of claims and to verify the correct edit files are used in processing claims. While DOH downloaded and sent the correct files to the third-party, it did not independently verify the third-party?s use of the updated edit files during the fiscal year. Because DHHS did not verify the use of the correct edit files, inaccurate, incomplete, or false claims could be paid.Recommendation:We recommend DHHS establish a system of regularly checking its third-party?s NCCI edits to ensure the correct edit files are used.DHHS?s Response and Corrective Action Plan:The Department concurs with this recommendation. The Division successfully created and tested a comparison file. The division will continue to work to resolve audit concerns. Implementation in production is set for November 2022.
Sufficiently-Detailed PIC Meeting Minutes Not Maintained(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS?s Program Integrity Committee (PIC) did not have well-documented meeting minutes showing the Office of Inspector General (OIG) reporting on utilization, fraud, waste, abuse, and recovery of Medicaid funds. 2 CFR 200.303 states that non-federal entities must ?establish and maintain effective internal control? that provides reasonable assurance that the non-federal entity is managing [the program] in compliance with? terms and conditions of the federal award.? PIC meetings were established so DHHS and OIG would meet monthly and report on utilization, fraud, waste, abuse, and recovery of Medicaid funds. However, it was recorded in only one of the seven monthly PIC meeting minutes that OIG reported on the required items. Staff turnover led to poorly recorded meeting minutes, which can result in incomplete, inaccurate, or untimely reporting of Medicaid funds abuse.Recommendation:We recommend that DHHS maintain detailed meeting minutes for its PIC meetings.DHHS?s Response:The Department concurs with this recommendation. The MOU between OIG and DIH/Medicaid and the PIC bylaws define that meeting minutes will be taken with each PIC Committee. These meeting minutes will be reviewed at the following PIC Committee meeting and voted on for approval.PIC bylaws specifically state:?To keep written minutes of all Committee meetings, with assistance of staff, including:? Date, time, and place of meeting;? Names of members present, absent, and excused;? Substance of all matters proposed, discussed or decided and a record of votes taken;? Names of all other individuals who appeared and the substance in brief of their testimony;? Any other information that any member requests to be entered in the minutes.?
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.
Foster Care Eligibility Controls Not Completed in a Timely Manner(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.658 Foster Care Title IV-EFederal Award Number: 2201UTFOST; 2101UTFOSTQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor 16 of 40 (40%) of cases reviewed, the State of Utah?s Department of Health & Human Services (DHHS) could not provide evidence that it had reviewed the initial Title IV-E Foster Care eligibility decision. 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.? The control was not properly designed and implemented as only two people (one of which is only a part time worker with responsibilities for other programs) were working on reviews for all Foster Care cases. The available resources are insufficient to complete these reviews in a timely manner. Unreviewed or untimely reviews of eligibility decisions could lead to improper eligibility determinations and inappropriate benefit payments.Recommendation:We recommend DHHS provide sufficient resources to carry out the existing control or modify the control to ensure eligibility decisions are reviewed in a timely manner.DHHS?s Response:The Department concurs with this recommendation. The agency is in the process of building an integrated eligibility team and will increase its capacity by having three team leads and one support coordinator III to support the eligibility review process.
Foster Care Eligibility Controls Not Completed in a Timely Manner(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.658 Foster Care Title IV-EFederal Award Number: 2201UTFOST; 2101UTFOSTQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor 16 of 40 (40%) of cases reviewed, the State of Utah?s Department of Health & Human Services (DHHS) could not provide evidence that it had reviewed the initial Title IV-E Foster Care eligibility decision. 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.? The control was not properly designed and implemented as only two people (one of which is only a part time worker with responsibilities for other programs) were working on reviews for all Foster Care cases. The available resources are insufficient to complete these reviews in a timely manner. Unreviewed or untimely reviews of eligibility decisions could lead to improper eligibility determinations and inappropriate benefit payments.Recommendation:We recommend DHHS provide sufficient resources to carry out the existing control or modify the control to ensure eligibility decisions are reviewed in a timely manner.DHHS?s Response:The Department concurs with this recommendation. The agency is in the process of building an integrated eligibility team and will increase its capacity by having three team leads and one support coordinator III to support the eligibility review process.
Subawards for SAPT Not Included in FFATA Reports(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.959 Substance Abuse and Prevention TreatmentFederal Award Number: 6B08TI010052-19M0016B08TI083039-01M0046B08TI083479-01M0041B08TI083546-016B08TI084674-01M002Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS did not have adequate controls implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. None of the Substance Abuse and Prevention Treatment (SAPT) subawards with FFATA reporting requirements were reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Since DHHS was unable to provide a SAPT subaward list, we could not determine the number of subawards and associated dollar amounts that should have been reported in FSRS.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 DHHS ?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 in FSRS ?no later than the end of the month following the month in which the obligation was made.? Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DHHS improve internal controls to capture applicable subawards in order to ensure accurate and timely FFATA reporting.DHHS?s Response:The Department concurs with this recommendation. We agree to properly report the subaward information beginning with SFY23.
Subawards for SAPT Not Included in FFATA Reports(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.959 Substance Abuse and Prevention TreatmentFederal Award Number: 6B08TI010052-19M0016B08TI083039-01M0046B08TI083479-01M0041B08TI083546-016B08TI084674-01M002Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS did not have adequate controls implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. None of the Substance Abuse and Prevention Treatment (SAPT) subawards with FFATA reporting requirements were reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Since DHHS was unable to provide a SAPT subaward list, we could not determine the number of subawards and associated dollar amounts that should have been reported in FSRS.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 DHHS ?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 in FSRS ?no later than the end of the month following the month in which the obligation was made.? Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DHHS improve internal controls to capture applicable subawards in order to ensure accurate and timely FFATA reporting.DHHS?s Response:The Department concurs with this recommendation. We agree to properly report the subaward information beginning with SFY23.
Finding 2022-001Federal Program Title ? COVID-19 Education Stabilization Fund ? Student PortionAssistance Listing No. ? 84.425EFederal Agency ? U.S. Department of Education (ED or the Department)Grant Award Period ? April 25, 2020 to May 15, 2022Compliance Requirement ? ReportingCriteriaThe University received funding under the federal Coronavirus Aid, Relief, and Economic Security(CARES) Act (HEERF I), Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA)(HEERF II) and the America Rescue Plan (ARP) (HEERF III).ED requires that institutions publicly post certain information on their website. The following informationmust appear in a format and location that is easily accessible to the public. This information must also beupdated no later than 10 days after the end of each calendar quarter (September 30, and December 31,March 31, June 30) thereafter:(1) An acknowledgement that the institution signed and returned to the Department the Certification andAgreement and the assurance that the institution has used the applicable amount of funds designatedunder the CRRSAA and ARP (a)(1) and (a)(4) programs to provide Emergency Financial Aid Grants toStudents.(2) The total amount of funds that the institution will receive or has received from the Department pursuantto the institution?s Certification and Agreement for Emergency Financial Aid Grants to Students under theCRRSAA and ARP (a)(1) and (a)(4) programs.(3) The total amount of Emergency Financial Aid Grants distributed to students under the CRRSAA andARP (a)(1) and (a)(4) programs as of the date of submission (i.e., as of the initial report and every calendarquarter thereafter).(4) The estimated total number of students at the institution that are eligible to receive Emergency FinancialAid Grants to Students under the CRRSAA and ARP (a)(1) and (a)(4) programs.(5) The total number of students who have received an Emergency Financial Aid Grant to students underthe CRRSAA and ARP (a)(1) and (a)(4) programs.(6) The method(s) used by the institution to determine which students receive Emergency Financial AidGrants and how much they would receive under the CRRSAA and ARP (a)(1) and (a)(4) programs.(7) Any instructions, directions, or guidance provided by the institution to students concerning theEmergency Financial Aid Grants.In addition, CFR 200.303 requires nonfederal entities to, among other things, establish and maintaineffective internal control over the Federal award that provides reasonable assurance that the non Federalentity is managing the Federal award in compliance with Federal statutes, regulations, and the terms andconditions of the Federal award.Conditions Found:During the audit, we noted the required information for funds received and disbursed for student aid underHEERF I and HEERF II were reported on the University?s website within required timeframes, with finalinformation for HEERF II reported as of March 15, 2022. Final information for HEERF I was previouslyreported within required timeframes. No quarterly information on the funding received for HEERF III wasincluded in the reporting during the fiscal year, although approximately $4.4M of HEERF III student aid wasawarded and disbursed during the fiscal year.On July 11, 2022, a student aid report was posted to the University?s website as a PDF related to thequarter ended March 31, 2022. Reporting for this quarter was due by April 10, 2022. This informationincluded student aid awarded of $7,781 and number of students awarded of 4 for the quarter endedMarch 31, 2022, and cumulative student aid paid for all HEERF awards as of March 31, 2022. Noinformation was presented for cumulative students receiving aid to date.No additional student aid information was reported until November 7, 2022. An update was posted to theUniversity?s website on November 7, 2022, indicating cumulative information of amounts received,disbursed, and number of students eligible and awarded for HEERF I, HEERF II, and HEERF III as ofAugust 30, 2022. No additional quarterly information was presented. Information surrounding the methodthe University used was also included for each award. As of August 30, 2022, all student aid had beenexpended.Questioned CostNo questioned costs were identified.Cause and EffectDue to competing job priorities, the University did not submit all required quarterly reports for student aidawarded and disbursed under HEERF III. The University did not have an effective system of internal controlin place, as prescribed by 2 CFR 200.303, to ensure the University completed quarterly reports timely.Repeat FindingA similar finding was not reported in the prior year audit.Statistical SamplingThe sample was not intended to be, and was not, a statistically valid sample.RecommendationsWe recommend the University enhance its internal control process to ensure the University has effectiveinternal controls in place in relation to completing its reporting on a timely manner.Views of Responsible OfficialThe University concurs with the findings. Appropriate reporting was completed for HEERF I and HEERF IIand annual reports completed timely. We have executed our corrective action plan to ensure quarterlyreports for HEERF III and other future reports are completed timely.
Reference Number:2022-002Prior Year Finding:NoFederal Agency:U.S. Department of AgricultureState Agency:Department of AgricultureFederal Program:Child Nutrition ClusterAssistance Listing Number:10.553, 10.555, 10.556, 10.559, 10.582Award Number and Year:INJ300304 (10/1/2020-9/30/2022)Compliance Requirement:Reporting ? Federal Funding Accountability and Transparency Act (FFATA)Type of FindingMaterial Weakness in Internal Control Over Compliance, Material Non-complianceCriteria or specific requirement:Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements.The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.)Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Agriculture (Department) did not report subaward information timely to FSRS during FY 2022.Context:Eight of eight subawards selected for testing were issued on 10/1/2021 and were not reported to FSRS until 9/30/2022, or 304 days late.SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLECause:The Department?s internal controls were not sufficient to ensure that subawards were reported timely to FSRS during FY 2022.Effect:Subawards were not reported to FSRS in accordance with FFATA requirements.Questioned costs:None noted.Recommendation:We recommend that the Department develop internal controls and procedures to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements.Views of responsible officials:The Department of Agriculture, Division of Food and Nutrition (DOA) was delinquent in submitting required reporting in the FFFATA Subaward Reporting System (FSRS) due to the inability to make system updates for the UEI change during the pandemic. This prevented the DOA from pulling data to submit the reports to the FSRS. The DOA has two technical staff members assigned to query the data fields required to upload the report. Once the query is complete the data is converted to a CSV file and uploaded to FSRS. As of December 2022, monthly reporting has resumed. Successful monthly upload documentation will now be provided and monitored by the Assistant Division Director and Fiscal Coordinator.
Reference Number:2022-002Prior Year Finding:NoFederal Agency:U.S. Department of AgricultureState Agency:Department of AgricultureFederal Program:Child Nutrition ClusterAssistance Listing Number:10.553, 10.555, 10.556, 10.559, 10.582Award Number and Year:INJ300304 (10/1/2020-9/30/2022)Compliance Requirement:Reporting ? Federal Funding Accountability and Transparency Act (FFATA)Type of FindingMaterial Weakness in Internal Control Over Compliance, Material Non-complianceCriteria or specific requirement:Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements.The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.)Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Agriculture (Department) did not report subaward information timely to FSRS during FY 2022.Context:Eight of eight subawards selected for testing were issued on 10/1/2021 and were not reported to FSRS until 9/30/2022, or 304 days late.SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLECause:The Department?s internal controls were not sufficient to ensure that subawards were reported timely to FSRS during FY 2022.Effect:Subawards were not reported to FSRS in accordance with FFATA requirements.Questioned costs:None noted.Recommendation:We recommend that the Department develop internal controls and procedures to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements.Views of responsible officials:The Department of Agriculture, Division of Food and Nutrition (DOA) was delinquent in submitting required reporting in the FFFATA Subaward Reporting System (FSRS) due to the inability to make system updates for the UEI change during the pandemic. This prevented the DOA from pulling data to submit the reports to the FSRS. The DOA has two technical staff members assigned to query the data fields required to upload the report. Once the query is complete the data is converted to a CSV file and uploaded to FSRS. As of December 2022, monthly reporting has resumed. Successful monthly upload documentation will now be provided and monitored by the Assistant Division Director and Fiscal Coordinator.
Reference Number:2022-002Prior Year Finding:NoFederal Agency:U.S. Department of AgricultureState Agency:Department of AgricultureFederal Program:Child Nutrition ClusterAssistance Listing Number:10.553, 10.555, 10.556, 10.559, 10.582Award Number and Year:INJ300304 (10/1/2020-9/30/2022)Compliance Requirement:Reporting ? Federal Funding Accountability and Transparency Act (FFATA)Type of FindingMaterial Weakness in Internal Control Over Compliance, Material Non-complianceCriteria or specific requirement:Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements.The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.)Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Agriculture (Department) did not report subaward information timely to FSRS during FY 2022.Context:Eight of eight subawards selected for testing were issued on 10/1/2021 and were not reported to FSRS until 9/30/2022, or 304 days late.SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLECause:The Department?s internal controls were not sufficient to ensure that subawards were reported timely to FSRS during FY 2022.Effect:Subawards were not reported to FSRS in accordance with FFATA requirements.Questioned costs:None noted.Recommendation:We recommend that the Department develop internal controls and procedures to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements.Views of responsible officials:The Department of Agriculture, Division of Food and Nutrition (DOA) was delinquent in submitting required reporting in the FFFATA Subaward Reporting System (FSRS) due to the inability to make system updates for the UEI change during the pandemic. This prevented the DOA from pulling data to submit the reports to the FSRS. The DOA has two technical staff members assigned to query the data fields required to upload the report. Once the query is complete the data is converted to a CSV file and uploaded to FSRS. As of December 2022, monthly reporting has resumed. Successful monthly upload documentation will now be provided and monitored by the Assistant Division Director and Fiscal Coordinator.
Reference Number:2022-002Prior Year Finding:NoFederal Agency:U.S. Department of AgricultureState Agency:Department of AgricultureFederal Program:Child Nutrition ClusterAssistance Listing Number:10.553, 10.555, 10.556, 10.559, 10.582Award Number and Year:INJ300304 (10/1/2020-9/30/2022)Compliance Requirement:Reporting ? Federal Funding Accountability and Transparency Act (FFATA)Type of FindingMaterial Weakness in Internal Control Over Compliance, Material Non-complianceCriteria or specific requirement:Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements.The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.)Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Agriculture (Department) did not report subaward information timely to FSRS during FY 2022.Context:Eight of eight subawards selected for testing were issued on 10/1/2021 and were not reported to FSRS until 9/30/2022, or 304 days late.SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLECause:The Department?s internal controls were not sufficient to ensure that subawards were reported timely to FSRS during FY 2022.Effect:Subawards were not reported to FSRS in accordance with FFATA requirements.Questioned costs:None noted.Recommendation:We recommend that the Department develop internal controls and procedures to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements.Views of responsible officials:The Department of Agriculture, Division of Food and Nutrition (DOA) was delinquent in submitting required reporting in the FFFATA Subaward Reporting System (FSRS) due to the inability to make system updates for the UEI change during the pandemic. This prevented the DOA from pulling data to submit the reports to the FSRS. The DOA has two technical staff members assigned to query the data fields required to upload the report. Once the query is complete the data is converted to a CSV file and uploaded to FSRS. As of December 2022, monthly reporting has resumed. Successful monthly upload documentation will now be provided and monitored by the Assistant Division Director and Fiscal Coordinator.
Reference Number:2022-002Prior Year Finding:NoFederal Agency:U.S. Department of AgricultureState Agency:Department of AgricultureFederal Program:Child Nutrition ClusterAssistance Listing Number:10.553, 10.555, 10.556, 10.559, 10.582Award Number and Year:INJ300304 (10/1/2020-9/30/2022)Compliance Requirement:Reporting ? Federal Funding Accountability and Transparency Act (FFATA)Type of FindingMaterial Weakness in Internal Control Over Compliance, Material Non-complianceCriteria or specific requirement:Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements.The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.)Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Agriculture (Department) did not report subaward information timely to FSRS during FY 2022.Context:Eight of eight subawards selected for testing were issued on 10/1/2021 and were not reported to FSRS until 9/30/2022, or 304 days late.SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLECause:The Department?s internal controls were not sufficient to ensure that subawards were reported timely to FSRS during FY 2022.Effect:Subawards were not reported to FSRS in accordance with FFATA requirements.Questioned costs:None noted.Recommendation:We recommend that the Department develop internal controls and procedures to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements.Views of responsible officials:The Department of Agriculture, Division of Food and Nutrition (DOA) was delinquent in submitting required reporting in the FFFATA Subaward Reporting System (FSRS) due to the inability to make system updates for the UEI change during the pandemic. This prevented the DOA from pulling data to submit the reports to the FSRS. The DOA has two technical staff members assigned to query the data fields required to upload the report. Once the query is complete the data is converted to a CSV file and uploaded to FSRS. As of December 2022, monthly reporting has resumed. Successful monthly upload documentation will now be provided and monitored by the Assistant Division Director and Fiscal Coordinator.
Reference Number:2022-002Prior Year Finding:NoFederal Agency:U.S. Department of AgricultureState Agency:Department of AgricultureFederal Program:Child Nutrition ClusterAssistance Listing Number:10.553, 10.555, 10.556, 10.559, 10.582Award Number and Year:INJ300304 (10/1/2020-9/30/2022)Compliance Requirement:Reporting ? Federal Funding Accountability and Transparency Act (FFATA)Type of FindingMaterial Weakness in Internal Control Over Compliance, Material Non-complianceCriteria or specific requirement:Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements.The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.)Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Agriculture (Department) did not report subaward information timely to FSRS during FY 2022.Context:Eight of eight subawards selected for testing were issued on 10/1/2021 and were not reported to FSRS until 9/30/2022, or 304 days late.SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLECause:The Department?s internal controls were not sufficient to ensure that subawards were reported timely to FSRS during FY 2022.Effect:Subawards were not reported to FSRS in accordance with FFATA requirements.Questioned costs:None noted.Recommendation:We recommend that the Department develop internal controls and procedures to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements.Views of responsible officials:The Department of Agriculture, Division of Food and Nutrition (DOA) was delinquent in submitting required reporting in the FFFATA Subaward Reporting System (FSRS) due to the inability to make system updates for the UEI change during the pandemic. This prevented the DOA from pulling data to submit the reports to the FSRS. The DOA has two technical staff members assigned to query the data fields required to upload the report. Once the query is complete the data is converted to a CSV file and uploaded to FSRS. As of December 2022, monthly reporting has resumed. Successful monthly upload documentation will now be provided and monitored by the Assistant Division Director and Fiscal Coordinator.
Reference Number:2022-003Prior Year Finding:2021-007Federal Agency:U.S. Department of LaborState Agency:Department of Labor and Workforce DevelopmentFederal Program:Unemployment Insurance, COVID-19 - Unemployment InsuranceAssistance Listing Number:17.225Award Number and Year:UI-35663-21-55-A-34 (10/1/2020 ? 12/31/2023), UI-34510-20-60-A-34 (1/1/2020 ? 9/30/2021), UI-35959-21-60-A-34 (1/1/2021 ? 9/30/2022), UI-34073-20-55-A-34 (10/1/19 ? 12/31/22), UI-32614-19-55-A-34 (10/1/18 ? 12/31/21), UI-37238-22-55-A-34 (10/1/21 ? 12/31/24)Compliance Requirement:EligibilityType of Finding:Material Weakness in Internal Control Over Compliance, Material NoncomplianceCriteria or specific requirement:Compliance: Regular Unemployment Compensation (UC) Program ? Under state UC laws, a worker?s benefit rights depend on the amount of the worker?s wages and/or weeks of work in covered employment in a ?base period.? While most states define the base period as the first four of the last five completed calendar quarters prior to the filing of the claim, other base periods may be used. To qualify for benefits, a claimant must have earned a certain amount of wages or have worked a certain number of weeks or calendar quarters within the base period or meet some combination of wage and employment requirements. Some states require a waiting period of one week of total or partial unemployment before UC is payable. A ?waiting period? is a non-compensable period of unemployment in which the worker is otherwise eligible for benefits. To be eligible to receive UC, all states provide that a claimant must have been separated from suitable work for non-disqualifying reasons under state law (i.e., not because of such acts as leaving voluntarily without good cause or discharge for misconduct connected with work). After separation, he or she must be able and available for work, actively seeking work, legally authorized to work in the United States and must not have refused an offer of suitable work.Pandemic Unemployment Assistance (PUA) ? PUA provides benefits to covered individuals, who are those individuals not eligible for regular unemployment compensation (UC or extended benefits under state or federal law or Pandemic Emergency Unemployment Compensation (PEUC), including those who have exhausted all rights to such benefits. Covered individuals also include self-employed, those seeking part-time employment, individuals lacking sufficient work history, and those who otherwise do not qualify for regular unemployment compensation or extended benefits under state or federal law or PEUC.PUA is payable to individuals who are ineligible for regular UC, and are unemployed, partially unemployed, or unable or unavailable to work due to one of the COVID-19 related reasons identified Attachment I to UIPL No. 16-20, Change 5. Section 2102(a)(3)(A)(ii)(I) of the CARES Act included 10 specific COVID-19 related reasons. The Department, under the authority provided by Section 2102(a)(3)(A)(ii)(I)(kk) of the CARES Act, has added additional COVID-19 related reasons; these are discussed in more detail in Section 4.a. of UIPL No. 16-20, Change 5. While three of these new COVID-19 related reasons were introduced to states with the publication of UIPL No. 16-20, Change 5 on February 25, 2021, all COVID-19 related reasons apply retroactively to the beginning of the PUA program.Additionally, as described in Section 4.b.i. of UIPL No. 16-20, Change 5, paraphrasing of the COVID-19 related reasons is not permissible; individuals must be permitted to select more than one COVID-19 related reason; individuals must be permitted to select different COVID-19 related reasons each week; and individuals must be permitted to file and select no COVID-19 related reasons.Federal Pandemic Unemployment Compensation (FPUC) ? To be eligible for FPUC during the program dates described in Section 8 above, individuals must be eligible to receive at least $1 of underlying benefits for the week in question (including regular UC, UCFE, UCX, PEUC, PUA, EB, STC, TRA, DUA, and SEA). FPUC does not require the individual to submit a separate initial application or continued claim.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:CLA noted that ineligible claimants were being paid unemployment insurance. The Department of Labor and Workforce Development (DLWD) did not maintain an effective control environment over eligibility requirements of the New Jersey Local Office Online Payment System (NJLOOPS) for both FPUC and PUA.Context:Sixty claimants were selected for testing which included 24 claimants for Regular UC and Extended Benefits, 25 claimants for FPUC and 11 claimants for PUA. We noted the following exceptions:? FPUC: 2 of 25 claimants receiving benefits did not receive at least $1 of other benefits for the payment period.? PUA: 4 of 11 claimants receiving PUA did not identify a COVID-19 reason for their unemployment and were ineligible for the program.Questioned costs:$2,320 - The total amount of benefits received by ineligible recipients:? FPUC: $600? PUA: $1,720Cause:The Department began providing benefits to claimants before NJLOOPS had completed the eligibility determination process.Effect:Ineligible claimants received unemployment compensation benefits.Recommendation:We recommend the Department review and enhance procedures and controls to ensure that only eligible claimants receive unemployment compensation benefits.Views of responsible officials:The Department of Labor and Workforce Development (DLWD) has controls in place to only allow an FPUC payment to be made when an underlying Unemployment Insurance (UI) payment has also been processed. FPUC payments should not be issued to any claim without the underlying UI payment being made for the same week. The two FPUC payments issued and noted as exceptions during eligibility testing will be reviewed independently by DLWD to determine if the payments issued were to eligible recipients or not.For the PUA exceptions noted during Eligibility testing, overall the DLWD issued PUA payments to over 680,000 claimants during the COVID-19 pandemic. DLWD had controls in place to require a COVID related reason to make the claim PUA eligible and the weekly PUA certification required claimants to choose a COVID related reason for why they were out of work before they could get paid. The PUA payments in question will be reviewed independently by the DLWD to determine if the payments issued under PUA were appropriate or if they should have been paid instead under the regular UI program.
Reference Number:2022-004Prior Year Finding:2021-010Federal Agency:U.S. Department of LaborState Agency:Department of Labor and Workforce DevelopmentFederal Program:Unemployment Insurance, COVID-19 ? Unemployment InsuranceAssistance Listing Number:17.225Award Number and Year:UI-35663-21-55-A-34 (10/1/2020 ? 12/31/2023), UI-34510-20-60-A-34 (1/1/2020 ? 9/30/2021), UI-35959-21-60-A-34 (1/1/2021 ? 9/30/2022), UI-34073-20-55-A-34 (10/1/19 ? 12/31/22), UI-32614-19-55-A-34 (10/1/18 ? 12/31/21), UI-37238-22-55-A-34 (10/1/21 ? 12/31/24)Compliance Requirement:Reporting ? ETA 9050 and ETA 9052Type of Finding:Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance: The ETA 9050 ? Time Lapse of All First Payments except Workshare report contains monthly information on first payment time lapse. This report concerns the time it takes states to pay benefits to claimants for the first compensable week of unemployment. First Payments are considered timely at 14/21 days, Interstate and Intrastate UI, UCFE, and UCX, full and partial weeks. The report is due in the ETA National Office on the 20th of the month following the month to which the data relates.The ETA 9052 ? Nonmonetary Determination Time Lapse Detection report contains monthly information on the time it take states to issue nonmonetary determinations from the date the issues are first detected by the agency. Single-claimant and multi-claimant nonmonetary determinations are included in the report. Nonmonetary determinations made by organizational units such as Benefits Accuracy Measurement (BAM) and Benefit Payment Control (BPC) are also included in the report. Nonmonetary determinations are considered timely if completed within 21 days. The report is due in the ETA National Office on the 20th of the month following the month to which the data relates.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:Reports submitted by the Department of Labor and Workforce Development (Department) indicate that First Payment Time Lapse and Nonmonetary Determinations were untimely during FY 2022.Context:Four ETA 9050 and four ETA 9052 reports were selected for testing for the months of September 2021, November 2021, February 2022, and May 2022. We noted the following exceptions:? ETA 9050: 4 of 4 reports indicate that First Payments were made in more than 14/21 days.? ETA 9052: 4 of 4 reports indicate that nonmonetary determinations were completed in more than 21 days.Questioned costs:None noted.Cause:The Department?s procedures and controls were not operating effectively to ensure that first payments and nonmonetary determinations were completed timely.Effect:First Payments and Nonmonetary Determinations were not completed timely as required by the program.Recommendation:We recommend that the Department review its policies and procedures to ensure that it makes first payments within 14/21 days and that nonmonetary determinations are completed within 21 days per program requirements.Views of responsible officials:New Jersey continues to make progress towards meeting the first payment and non-monetary time lapse standards as recovery from the historic claims filing related to the COVID-19 pandemic continues. As indicated in the prior year update, time lapse standards for both first payment and non-monetary continue to increase from the lows seen during the pandemic. Most recent figures for February 2023 show first payment time lapse at 65.1% and year-to-date at 54.5%, both up from what was reported last November 2022 at 40% and 36.4%, respectively. Non-monetary time lapse figures have also improved, with the most recent February 2023 figures reported as 62.6% for the month and 44.1% year-to-date, which is up from 24.0% for March 2022 and year-to-date at that time of 33.0%).It is important to note that before the pandemic hit in March 2020, New Jersey current figures at that time met all first payment and non-monetary time lapse standards for the reporting year that ended March 2020. The decrease to the timeliness figures is a direct result of the significant increase to workload volumes resulting from the pandemic and not due to a lack of proper internal controls.In addition to the high workloads, New Jersey has also implemented strict anti-fraud measures that include all new claims filed going through an identity proofing process before any payments can be issued. Delays on the claimant end to complete the verification process ? either by the claimant not going through the process or having difficulty with completing it ? also will have a direct impact on first payment time lapse. Increased education to claimants on the requirement to verify their ID, as well as increasing the tools and greater availability of support for ID verification will provide claimants with more options to meet this requirement. New Jersey has worked with our identity verification partner to allow for three different methods of verification; 1) self-service online, 2) connect to a `Trusted Referee? with our identity verification partner who will provide the verification online through a video call, or 3) an in-person appointment at a walk-in center to complete the process. In addition to what is offered by the vendor, One Stop centers throughout the State have been equipped with upgraded monitors with cameras that will allow claimants that are unable to complete the process with our vendor to report to one of these centers and complete the process there.As New Jersey continues to work through the backlog of claims, it is anticipated that overall time lapse figures will continue to improve and for the reporting year ending March 2024 progress will be made towards meeting the established standards.
Reference Number:2022-005Prior Year Finding:NoFederal Agency:U.S. Department of LaborState Agency:Department of Labor and Workforce DevelopmentFederal Program:Unemployment Insurance, COVID-19 ? Unemployment InsuranceAssistance Listing Number:17.225Award Number and Year:UI-35663-21-55-A-34 (10/1/2020 ? 12/31/2023), UI-34510-20-60-A-34 (1/1/2020 ? 9/30/2021), UI-35959-21-60-A-34 (1/1/2021 ? 9/30/2022), UI-34073-20-55-A-34 (10/1/19 ? 12/31/22), UI-32614-19-55-A-34 (10/1/18 ? 12/31/21), UI-37238-22-55-A-34 (10/1/21 ? 12/31/24)Compliance Requirement:Special Tests and Provisions: UI Reemployment Programs: RESEAType of Finding:Significant Deficiency in Internal Control over Compliance, Other MattersCriteria or specific requirement:Compliance: Per 42 U.S. Code ? 506 (a) The Secretary of Labor (in this section referred to as the ?Secretary?) shall award grants under this section for a fiscal year to eligible States to conduct a program of reemployment services and eligibility assessments for individuals referred to reemployment services as described in section 503(j) of this title for weeks in such fiscal year for which such individuals receive unemployment compensation. Further, per 42 U.S. Code ? 506 (c) (1), In carrying out a State program of reemployment services and eligibility assessments using grant funds awarded to the State under this section, a State shall use such funds only for interventions demonstrated to reduce the number of weeks for which program participants receive unemployment compensation by improving employment outcomes for program participants.The UI program serves as one of the principal ?gateways? to the workforce system. It is often the first workforce program accessed by individuals who need workforce services. The WPRS and RESEA programs serve as UI?s primary programs that facilitate the reemployment needs of UI claimants.WPRS, which is mandated by Section 303(j) of the Social Security Act, is designed to identify UI claimants who are most likely to exhaust their benefits and need reemployment assistance to return to work, and refer them to appropriate reemployment services, such as: job search and job placement assistance; counseling; testing; provision of occupational and labor market information; and assessments. WPRS provides reemployment services to selected claimants through an early intervention process. The number of individuals served under WPRS is determined by the state (and/or local areas) based on its capacity to serve these individuals. UIPL No. 41-94 provides guidance on WPRS requirements.RESEA is authorized by Section 306 of the Social Security Act and builds on the success of RESEA?s predecessor, the former UI Reemployment and Eligibility Assessment (REA) program. RESEA uses an evidence-based integrated approach that combines an eligibility assessment for continuing UI eligibility and the provision of reemployment services. State administration of the RESEA is voluntary and under certain circumstances may be designed to also satisfy WPRS requirements. Operating guidance for the RESEA program is updated annually. UIPL 13-21 provides RESEA operating Guidance for FY 2021.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 be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Labor (Department) did not retain documentation required by the RESEA program to verify compliance with federal program regulations. Controls were not working sufficiently to document that a staff member at the Department with knowledge of the program reviewed eligibility requirements prior to admission of participants to the RESEA program.Context:The Department?s policy is that RESEA eligibility interviews must be conducted and eligibility review forms completed. Both steps are to be reviewed and signed by the participant and an Unemployment Insurance (UI) staff member who is knowledgeable of the program requirements. For three of sixty cases selected for testing, the Department was unable to provide a signed RESEA worksheet indicating the interview had been completed and the claimant was reviewed and approved by a UI supervisor.Questioned costs:Undetermined.Cause:The Department?s procedures and internal controls are not sufficient to ensure compliance with RESEA requirements.Effect:Without clear documentation supporting a participant?s eligibility and supervisory review, ineligible participants could go undetected and federal funds could be paid to recipients who do not qualify to participate in the RESEA program.Recommendation:We recommend that policies and procedures be implemented to ensure that internal controls over RESEA include retention of documentation of each participant?s eligibility and review and approval by a UI supervisor.Views of responsible officials:The RESEA policy and controls presently in place at the Department of Labor and Workforce Development (DLWD) require eligibility interviews to be conducted and eligibility review forms to be completed and signed by the participant and UI program representative. DLWD will work to strengthen and reinforce these controls with responsible staff in an effort to ensure that all interviews are properly documented and eligibility review forms are signed and maintained on file for future reference and compliance support.
Reference Number: 2022-006Prior Year Finding: 2021-012Federal Agency: U.S. Department of LaborState Agency: Department of Labor and Workforce DevelopmentFederal Program: Unemployment InsuranceAssistance Listing Number: 17.225Award Number and Year: UI-35663-21-55-A-34 (10/1/2020 ? 12/31/2023), UI-34510-20-60-A-34 (1/1/2020 ? 9/30/2021), UI-35959-21-60-A-34 (1/1/2021 ? 9/30/2022)Compliance Requirement: Information Technology General ControlsType of Finding Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement: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). As part of an entity?s internal controls to reasonably ensure compliance over Federal laws and regulations, an entity must maintain an effective control environment over their information technology systems used to generate and process information to administer Federal programs in accordance with the respective rules and regulations that govern the program.Condition:The Department of Labor and Workforce Development (Department) did not maintain an effective control environment over change management of the New Jersey Local Office Online Payment System (NJLOOPS).Context:The NJLOOPS application is an essential system hosted within the Office of Information Technology?s (OIT) infrastructure used by the Department for unemployment insurance eligibility, claims, benefit calculations, and payments. NJLOOPS application management is provided by Department staff. We noted that the prior year finding for internal controls over change management was not corrected. Specifically, we noted that while tickets have been documented for the sample of changes tested for the NJLOOPS change management procedures, they do not maintain key information described in the change management policy. Further, we noted that two individuals have the ability to develop and promote their own changes to production which poses a segregation of duties issue.Questioned costs:Undetermined.Cause:Due to limitations on staffing and increased demand on IT resources due to the additional requirements of the pandemic's unemployment program, the agency was unable to comply with its internal change management procedures requirements.Effect:Noncompliance with the requirements of internal change management procedures and a lack of segregation of duties could increase the risk of potential unauthorized or unapproved changes occurring to the application.Recommendation:We recommend the Department follow the statewide change management policy and formally document the request, testing, and approval of all changes related to the NJLOOPS application. We further recommend that the Department implement segregation of duties controls to prevent the same user from developing, approving, and promoting a system change to the production environment.Views of responsible officials:The Department of Labor and Workforce Development (DLWD) Office of Information Management, Services & Solutions (OIMSS) will continue its efforts to strengthen and improve staff compliance with existing controls over program change controls for the New Jersey Local Office Online Payment System (NJLOOPs). OIMSS management will conduct a meeting with all staff involved in program changes to reiterate that existing control requirements must be adhered to at all times. DLWD expects to achieve full compliance with exiting controls by June 30, 2023.
Reference Number:2022-003Prior Year Finding:2021-007Federal Agency:U.S. Department of LaborState Agency:Department of Labor and Workforce DevelopmentFederal Program:Unemployment Insurance, COVID-19 - Unemployment InsuranceAssistance Listing Number:17.225Award Number and Year:UI-35663-21-55-A-34 (10/1/2020 ? 12/31/2023), UI-34510-20-60-A-34 (1/1/2020 ? 9/30/2021), UI-35959-21-60-A-34 (1/1/2021 ? 9/30/2022), UI-34073-20-55-A-34 (10/1/19 ? 12/31/22), UI-32614-19-55-A-34 (10/1/18 ? 12/31/21), UI-37238-22-55-A-34 (10/1/21 ? 12/31/24)Compliance Requirement:EligibilityType of Finding:Material Weakness in Internal Control Over Compliance, Material NoncomplianceCriteria or specific requirement:Compliance: Regular Unemployment Compensation (UC) Program ? Under state UC laws, a worker?s benefit rights depend on the amount of the worker?s wages and/or weeks of work in covered employment in a ?base period.? While most states define the base period as the first four of the last five completed calendar quarters prior to the filing of the claim, other base periods may be used. To qualify for benefits, a claimant must have earned a certain amount of wages or have worked a certain number of weeks or calendar quarters within the base period or meet some combination of wage and employment requirements. Some states require a waiting period of one week of total or partial unemployment before UC is payable. A ?waiting period? is a non-compensable period of unemployment in which the worker is otherwise eligible for benefits. To be eligible to receive UC, all states provide that a claimant must have been separated from suitable work for non-disqualifying reasons under state law (i.e., not because of such acts as leaving voluntarily without good cause or discharge for misconduct connected with work). After separation, he or she must be able and available for work, actively seeking work, legally authorized to work in the United States and must not have refused an offer of suitable work.Pandemic Unemployment Assistance (PUA) ? PUA provides benefits to covered individuals, who are those individuals not eligible for regular unemployment compensation (UC or extended benefits under state or federal law or Pandemic Emergency Unemployment Compensation (PEUC), including those who have exhausted all rights to such benefits. Covered individuals also include self-employed, those seeking part-time employment, individuals lacking sufficient work history, and those who otherwise do not qualify for regular unemployment compensation or extended benefits under state or federal law or PEUC.PUA is payable to individuals who are ineligible for regular UC, and are unemployed, partially unemployed, or unable or unavailable to work due to one of the COVID-19 related reasons identified Attachment I to UIPL No. 16-20, Change 5. Section 2102(a)(3)(A)(ii)(I) of the CARES Act included 10 specific COVID-19 related reasons. The Department, under the authority provided by Section 2102(a)(3)(A)(ii)(I)(kk) of the CARES Act, has added additional COVID-19 related reasons; these are discussed in more detail in Section 4.a. of UIPL No. 16-20, Change 5. While three of these new COVID-19 related reasons were introduced to states with the publication of UIPL No. 16-20, Change 5 on February 25, 2021, all COVID-19 related reasons apply retroactively to the beginning of the PUA program.Additionally, as described in Section 4.b.i. of UIPL No. 16-20, Change 5, paraphrasing of the COVID-19 related reasons is not permissible; individuals must be permitted to select more than one COVID-19 related reason; individuals must be permitted to select different COVID-19 related reasons each week; and individuals must be permitted to file and select no COVID-19 related reasons.Federal Pandemic Unemployment Compensation (FPUC) ? To be eligible for FPUC during the program dates described in Section 8 above, individuals must be eligible to receive at least $1 of underlying benefits for the week in question (including regular UC, UCFE, UCX, PEUC, PUA, EB, STC, TRA, DUA, and SEA). FPUC does not require the individual to submit a separate initial application or continued claim.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:CLA noted that ineligible claimants were being paid unemployment insurance. The Department of Labor and Workforce Development (DLWD) did not maintain an effective control environment over eligibility requirements of the New Jersey Local Office Online Payment System (NJLOOPS) for both FPUC and PUA.Context:Sixty claimants were selected for testing which included 24 claimants for Regular UC and Extended Benefits, 25 claimants for FPUC and 11 claimants for PUA. We noted the following exceptions:? FPUC: 2 of 25 claimants receiving benefits did not receive at least $1 of other benefits for the payment period.? PUA: 4 of 11 claimants receiving PUA did not identify a COVID-19 reason for their unemployment and were ineligible for the program.Questioned costs:$2,320 - The total amount of benefits received by ineligible recipients:? FPUC: $600? PUA: $1,720Cause:The Department began providing benefits to claimants before NJLOOPS had completed the eligibility determination process.Effect:Ineligible claimants received unemployment compensation benefits.Recommendation:We recommend the Department review and enhance procedures and controls to ensure that only eligible claimants receive unemployment compensation benefits.Views of responsible officials:The Department of Labor and Workforce Development (DLWD) has controls in place to only allow an FPUC payment to be made when an underlying Unemployment Insurance (UI) payment has also been processed. FPUC payments should not be issued to any claim without the underlying UI payment being made for the same week. The two FPUC payments issued and noted as exceptions during eligibility testing will be reviewed independently by DLWD to determine if the payments issued were to eligible recipients or not.For the PUA exceptions noted during Eligibility testing, overall the DLWD issued PUA payments to over 680,000 claimants during the COVID-19 pandemic. DLWD had controls in place to require a COVID related reason to make the claim PUA eligible and the weekly PUA certification required claimants to choose a COVID related reason for why they were out of work before they could get paid. The PUA payments in question will be reviewed independently by the DLWD to determine if the payments issued under PUA were appropriate or if they should have been paid instead under the regular UI program.
Reference Number:2022-004Prior Year Finding:2021-010Federal Agency:U.S. Department of LaborState Agency:Department of Labor and Workforce DevelopmentFederal Program:Unemployment Insurance, COVID-19 ? Unemployment InsuranceAssistance Listing Number:17.225Award Number and Year:UI-35663-21-55-A-34 (10/1/2020 ? 12/31/2023), UI-34510-20-60-A-34 (1/1/2020 ? 9/30/2021), UI-35959-21-60-A-34 (1/1/2021 ? 9/30/2022), UI-34073-20-55-A-34 (10/1/19 ? 12/31/22), UI-32614-19-55-A-34 (10/1/18 ? 12/31/21), UI-37238-22-55-A-34 (10/1/21 ? 12/31/24)Compliance Requirement:Reporting ? ETA 9050 and ETA 9052Type of Finding:Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance: The ETA 9050 ? Time Lapse of All First Payments except Workshare report contains monthly information on first payment time lapse. This report concerns the time it takes states to pay benefits to claimants for the first compensable week of unemployment. First Payments are considered timely at 14/21 days, Interstate and Intrastate UI, UCFE, and UCX, full and partial weeks. The report is due in the ETA National Office on the 20th of the month following the month to which the data relates.The ETA 9052 ? Nonmonetary Determination Time Lapse Detection report contains monthly information on the time it take states to issue nonmonetary determinations from the date the issues are first detected by the agency. Single-claimant and multi-claimant nonmonetary determinations are included in the report. Nonmonetary determinations made by organizational units such as Benefits Accuracy Measurement (BAM) and Benefit Payment Control (BPC) are also included in the report. Nonmonetary determinations are considered timely if completed within 21 days. The report is due in the ETA National Office on the 20th of the month following the month to which the data relates.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:Reports submitted by the Department of Labor and Workforce Development (Department) indicate that First Payment Time Lapse and Nonmonetary Determinations were untimely during FY 2022.Context:Four ETA 9050 and four ETA 9052 reports were selected for testing for the months of September 2021, November 2021, February 2022, and May 2022. We noted the following exceptions:? ETA 9050: 4 of 4 reports indicate that First Payments were made in more than 14/21 days.? ETA 9052: 4 of 4 reports indicate that nonmonetary determinations were completed in more than 21 days.Questioned costs:None noted.Cause:The Department?s procedures and controls were not operating effectively to ensure that first payments and nonmonetary determinations were completed timely.Effect:First Payments and Nonmonetary Determinations were not completed timely as required by the program.Recommendation:We recommend that the Department review its policies and procedures to ensure that it makes first payments within 14/21 days and that nonmonetary determinations are completed within 21 days per program requirements.Views of responsible officials:New Jersey continues to make progress towards meeting the first payment and non-monetary time lapse standards as recovery from the historic claims filing related to the COVID-19 pandemic continues. As indicated in the prior year update, time lapse standards for both first payment and non-monetary continue to increase from the lows seen during the pandemic. Most recent figures for February 2023 show first payment time lapse at 65.1% and year-to-date at 54.5%, both up from what was reported last November 2022 at 40% and 36.4%, respectively. Non-monetary time lapse figures have also improved, with the most recent February 2023 figures reported as 62.6% for the month and 44.1% year-to-date, which is up from 24.0% for March 2022 and year-to-date at that time of 33.0%).It is important to note that before the pandemic hit in March 2020, New Jersey current figures at that time met all first payment and non-monetary time lapse standards for the reporting year that ended March 2020. The decrease to the timeliness figures is a direct result of the significant increase to workload volumes resulting from the pandemic and not due to a lack of proper internal controls.In addition to the high workloads, New Jersey has also implemented strict anti-fraud measures that include all new claims filed going through an identity proofing process before any payments can be issued. Delays on the claimant end to complete the verification process ? either by the claimant not going through the process or having difficulty with completing it ? also will have a direct impact on first payment time lapse. Increased education to claimants on the requirement to verify their ID, as well as increasing the tools and greater availability of support for ID verification will provide claimants with more options to meet this requirement. New Jersey has worked with our identity verification partner to allow for three different methods of verification; 1) self-service online, 2) connect to a `Trusted Referee? with our identity verification partner who will provide the verification online through a video call, or 3) an in-person appointment at a walk-in center to complete the process. In addition to what is offered by the vendor, One Stop centers throughout the State have been equipped with upgraded monitors with cameras that will allow claimants that are unable to complete the process with our vendor to report to one of these centers and complete the process there.As New Jersey continues to work through the backlog of claims, it is anticipated that overall time lapse figures will continue to improve and for the reporting year ending March 2024 progress will be made towards meeting the established standards.
Reference Number:2022-005Prior Year Finding:NoFederal Agency:U.S. Department of LaborState Agency:Department of Labor and Workforce DevelopmentFederal Program:Unemployment Insurance, COVID-19 ? Unemployment InsuranceAssistance Listing Number:17.225Award Number and Year:UI-35663-21-55-A-34 (10/1/2020 ? 12/31/2023), UI-34510-20-60-A-34 (1/1/2020 ? 9/30/2021), UI-35959-21-60-A-34 (1/1/2021 ? 9/30/2022), UI-34073-20-55-A-34 (10/1/19 ? 12/31/22), UI-32614-19-55-A-34 (10/1/18 ? 12/31/21), UI-37238-22-55-A-34 (10/1/21 ? 12/31/24)Compliance Requirement:Special Tests and Provisions: UI Reemployment Programs: RESEAType of Finding:Significant Deficiency in Internal Control over Compliance, Other MattersCriteria or specific requirement:Compliance: Per 42 U.S. Code ? 506 (a) The Secretary of Labor (in this section referred to as the ?Secretary?) shall award grants under this section for a fiscal year to eligible States to conduct a program of reemployment services and eligibility assessments for individuals referred to reemployment services as described in section 503(j) of this title for weeks in such fiscal year for which such individuals receive unemployment compensation. Further, per 42 U.S. Code ? 506 (c) (1), In carrying out a State program of reemployment services and eligibility assessments using grant funds awarded to the State under this section, a State shall use such funds only for interventions demonstrated to reduce the number of weeks for which program participants receive unemployment compensation by improving employment outcomes for program participants.The UI program serves as one of the principal ?gateways? to the workforce system. It is often the first workforce program accessed by individuals who need workforce services. The WPRS and RESEA programs serve as UI?s primary programs that facilitate the reemployment needs of UI claimants.WPRS, which is mandated by Section 303(j) of the Social Security Act, is designed to identify UI claimants who are most likely to exhaust their benefits and need reemployment assistance to return to work, and refer them to appropriate reemployment services, such as: job search and job placement assistance; counseling; testing; provision of occupational and labor market information; and assessments. WPRS provides reemployment services to selected claimants through an early intervention process. The number of individuals served under WPRS is determined by the state (and/or local areas) based on its capacity to serve these individuals. UIPL No. 41-94 provides guidance on WPRS requirements.RESEA is authorized by Section 306 of the Social Security Act and builds on the success of RESEA?s predecessor, the former UI Reemployment and Eligibility Assessment (REA) program. RESEA uses an evidence-based integrated approach that combines an eligibility assessment for continuing UI eligibility and the provision of reemployment services. State administration of the RESEA is voluntary and under certain circumstances may be designed to also satisfy WPRS requirements. Operating guidance for the RESEA program is updated annually. UIPL 13-21 provides RESEA operating Guidance for FY 2021.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 be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Labor (Department) did not retain documentation required by the RESEA program to verify compliance with federal program regulations. Controls were not working sufficiently to document that a staff member at the Department with knowledge of the program reviewed eligibility requirements prior to admission of participants to the RESEA program.Context:The Department?s policy is that RESEA eligibility interviews must be conducted and eligibility review forms completed. Both steps are to be reviewed and signed by the participant and an Unemployment Insurance (UI) staff member who is knowledgeable of the program requirements. For three of sixty cases selected for testing, the Department was unable to provide a signed RESEA worksheet indicating the interview had been completed and the claimant was reviewed and approved by a UI supervisor.Questioned costs:Undetermined.Cause:The Department?s procedures and internal controls are not sufficient to ensure compliance with RESEA requirements.Effect:Without clear documentation supporting a participant?s eligibility and supervisory review, ineligible participants could go undetected and federal funds could be paid to recipients who do not qualify to participate in the RESEA program.Recommendation:We recommend that policies and procedures be implemented to ensure that internal controls over RESEA include retention of documentation of each participant?s eligibility and review and approval by a UI supervisor.Views of responsible officials:The RESEA policy and controls presently in place at the Department of Labor and Workforce Development (DLWD) require eligibility interviews to be conducted and eligibility review forms to be completed and signed by the participant and UI program representative. DLWD will work to strengthen and reinforce these controls with responsible staff in an effort to ensure that all interviews are properly documented and eligibility review forms are signed and maintained on file for future reference and compliance support.
Reference Number: 2022-006Prior Year Finding: 2021-012Federal Agency: U.S. Department of LaborState Agency: Department of Labor and Workforce DevelopmentFederal Program: Unemployment InsuranceAssistance Listing Number: 17.225Award Number and Year: UI-35663-21-55-A-34 (10/1/2020 ? 12/31/2023), UI-34510-20-60-A-34 (1/1/2020 ? 9/30/2021), UI-35959-21-60-A-34 (1/1/2021 ? 9/30/2022)Compliance Requirement: Information Technology General ControlsType of Finding Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement: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). As part of an entity?s internal controls to reasonably ensure compliance over Federal laws and regulations, an entity must maintain an effective control environment over their information technology systems used to generate and process information to administer Federal programs in accordance with the respective rules and regulations that govern the program.Condition:The Department of Labor and Workforce Development (Department) did not maintain an effective control environment over change management of the New Jersey Local Office Online Payment System (NJLOOPS).Context:The NJLOOPS application is an essential system hosted within the Office of Information Technology?s (OIT) infrastructure used by the Department for unemployment insurance eligibility, claims, benefit calculations, and payments. NJLOOPS application management is provided by Department staff. We noted that the prior year finding for internal controls over change management was not corrected. Specifically, we noted that while tickets have been documented for the sample of changes tested for the NJLOOPS change management procedures, they do not maintain key information described in the change management policy. Further, we noted that two individuals have the ability to develop and promote their own changes to production which poses a segregation of duties issue.Questioned costs:Undetermined.Cause:Due to limitations on staffing and increased demand on IT resources due to the additional requirements of the pandemic's unemployment program, the agency was unable to comply with its internal change management procedures requirements.Effect:Noncompliance with the requirements of internal change management procedures and a lack of segregation of duties could increase the risk of potential unauthorized or unapproved changes occurring to the application.Recommendation:We recommend the Department follow the statewide change management policy and formally document the request, testing, and approval of all changes related to the NJLOOPS application. We further recommend that the Department implement segregation of duties controls to prevent the same user from developing, approving, and promoting a system change to the production environment.Views of responsible officials:The Department of Labor and Workforce Development (DLWD) Office of Information Management, Services & Solutions (OIMSS) will continue its efforts to strengthen and improve staff compliance with existing controls over program change controls for the New Jersey Local Office Online Payment System (NJLOOPs). OIMSS management will conduct a meeting with all staff involved in program changes to reiterate that existing control requirements must be adhered to at all times. DLWD expects to achieve full compliance with exiting controls by June 30, 2023.
Reference Number:2022-007Prior Year Finding:NoFederal Agency:U.S. Department of LaborState Agency:Department of Labor and Workforce DevelopmentFederal Program:WIOA ClusterAssistance Listing Number:17.258, 17.259, 17.278Award Number and Year:AA-32176-18-55-A-34 (7/1/18 ? 9/30/21), AA-33245-19-55-A-34 (7/1/19 ? 9/30/22), AA-34783-20-55-A-34 (7/1/20 ? 9/30/23), AA-36334-21-55-A-34 (7/1/21 ? 9/30/24)Compliance Requirement:Reporting ? Federal Funding Accountability and Transparency Act (FFATA)Type of Finding:Material Weakness in Internal Control Over Compliance, Material Non-complianceCriteria or specific requirement:Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements.The following key data elements must be reported: Subawardee Name and Unique Entity ID (UEI) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.)Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Subaward information was not reported timely to FSRS during FY 2022.Context:Eight of eight subawards selected for testing were not reported timely to FSRS. Specifically, we noted the following exceptions:? 3 of 3 subawards issued on 7/1/2019 were reported to FSRS on 9/1/2021, or 733 days late.? 5 of 5 subawards issued between 7/1/2020 and 2/1/2022 were reported to FSRS on 2/6/2023, or between 343 and 951 days late.SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLECause:The Department?s internal controls were not sufficient to ensure that subawards were reported timely to FSRS during FY 2022.Effect:Subawards were not reported to FSRS in accordance with FFATA requirements.Questioned costs:None noted.Recommendation:We recommend that the Department develop internal controls and procedures to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements.Views of responsible officials:In recent years, the Department of Labor and Workforce Development (DLWD) has transitioned from a manual contract process to a web-based system (i.e., SAGE and IGX systems) and has also experienced changes in personnel responsible for the contracting process. Although progress has been made with getting the FFATA Reporting Unit access to these automated systems, the DLWD will continue to enhance the communication between the offices that prepare and approve the contracts/agreements and the FFATA Reporting Unit. DLWD will also develop procedures to ensure that timely and accurate information is provided to the FFATA Reporting Unit and that group will also be included in the grant approval process so the unit is notified timely.
Reference Number:2022-007Prior Year Finding:NoFederal Agency:U.S. Department of LaborState Agency:Department of Labor and Workforce DevelopmentFederal Program:WIOA ClusterAssistance Listing Number:17.258, 17.259, 17.278Award Number and Year:AA-32176-18-55-A-34 (7/1/18 ? 9/30/21), AA-33245-19-55-A-34 (7/1/19 ? 9/30/22), AA-34783-20-55-A-34 (7/1/20 ? 9/30/23), AA-36334-21-55-A-34 (7/1/21 ? 9/30/24)Compliance Requirement:Reporting ? Federal Funding Accountability and Transparency Act (FFATA)Type of Finding:Material Weakness in Internal Control Over Compliance, Material Non-complianceCriteria or specific requirement:Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements.The following key data elements must be reported: Subawardee Name and Unique Entity ID (UEI) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.)Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Subaward information was not reported timely to FSRS during FY 2022.Context:Eight of eight subawards selected for testing were not reported timely to FSRS. Specifically, we noted the following exceptions:? 3 of 3 subawards issued on 7/1/2019 were reported to FSRS on 9/1/2021, or 733 days late.? 5 of 5 subawards issued between 7/1/2020 and 2/1/2022 were reported to FSRS on 2/6/2023, or between 343 and 951 days late.SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLECause:The Department?s internal controls were not sufficient to ensure that subawards were reported timely to FSRS during FY 2022.Effect:Subawards were not reported to FSRS in accordance with FFATA requirements.Questioned costs:None noted.Recommendation:We recommend that the Department develop internal controls and procedures to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements.Views of responsible officials:In recent years, the Department of Labor and Workforce Development (DLWD) has transitioned from a manual contract process to a web-based system (i.e., SAGE and IGX systems) and has also experienced changes in personnel responsible for the contracting process. Although progress has been made with getting the FFATA Reporting Unit access to these automated systems, the DLWD will continue to enhance the communication between the offices that prepare and approve the contracts/agreements and the FFATA Reporting Unit. DLWD will also develop procedures to ensure that timely and accurate information is provided to the FFATA Reporting Unit and that group will also be included in the grant approval process so the unit is notified timely.
Reference Number:2022-007Prior Year Finding:NoFederal Agency:U.S. Department of LaborState Agency:Department of Labor and Workforce DevelopmentFederal Program:WIOA ClusterAssistance Listing Number:17.258, 17.259, 17.278Award Number and Year:AA-32176-18-55-A-34 (7/1/18 ? 9/30/21), AA-33245-19-55-A-34 (7/1/19 ? 9/30/22), AA-34783-20-55-A-34 (7/1/20 ? 9/30/23), AA-36334-21-55-A-34 (7/1/21 ? 9/30/24)Compliance Requirement:Reporting ? Federal Funding Accountability and Transparency Act (FFATA)Type of Finding:Material Weakness in Internal Control Over Compliance, Material Non-complianceCriteria or specific requirement:Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements.The following key data elements must be reported: Subawardee Name and Unique Entity ID (UEI) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.)Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Subaward information was not reported timely to FSRS during FY 2022.Context:Eight of eight subawards selected for testing were not reported timely to FSRS. Specifically, we noted the following exceptions:? 3 of 3 subawards issued on 7/1/2019 were reported to FSRS on 9/1/2021, or 733 days late.? 5 of 5 subawards issued between 7/1/2020 and 2/1/2022 were reported to FSRS on 2/6/2023, or between 343 and 951 days late.SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLECause:The Department?s internal controls were not sufficient to ensure that subawards were reported timely to FSRS during FY 2022.Effect:Subawards were not reported to FSRS in accordance with FFATA requirements.Questioned costs:None noted.Recommendation:We recommend that the Department develop internal controls and procedures to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements.Views of responsible officials:In recent years, the Department of Labor and Workforce Development (DLWD) has transitioned from a manual contract process to a web-based system (i.e., SAGE and IGX systems) and has also experienced changes in personnel responsible for the contracting process. Although progress has been made with getting the FFATA Reporting Unit access to these automated systems, the DLWD will continue to enhance the communication between the offices that prepare and approve the contracts/agreements and the FFATA Reporting Unit. DLWD will also develop procedures to ensure that timely and accurate information is provided to the FFATA Reporting Unit and that group will also be included in the grant approval process so the unit is notified timely.
Reference Number:2022-008Prior Year Finding:NoFederal Agency:U.S. Department of the TreasuryState Agency:Department of Community AffairsFederal Program:COVID-19 - Emergency Rental Assistance ProgramAssistance Listing Number:21.023Award Number and Year:ERA0222 (3/13/2020 ? 9/30/2025), ERAE0490 (3/13/2020 - 9/30/2025)Compliance Requirement:ReportingType of FindingMaterial Weakness in Internal Control Over Compliance, Material NoncomplianceCriteria or specific requirement:Compliance: Emergency Rental Assistance (ERA) 1 and ERA 2 state, local, and territorial recipients were required to submit monthly and quarterly reports to the United States Department of the Treasury (U.S. Treasury). The monthly reports are brief two-question updates through which ERA recipients provide U.S. Treasury with very high-level counts of the numbers of households receiving assistance and the amounts of ERA funds distributed. The quarterly reports are in-depth reports with data on an array of programmatic and financial information to provide transparency in the use and progress of ERA funds. Monthly reports were required for each month of Fiscal Year 2022 and were due 15 days after the end of the month. Quarterly reports were required for each quarter of Fiscal Year 2022 and were due October 29, 2021, February 1, 2022, April 15, 2022, and July 15, 2022.The Emergency Rental Assistance Program Reporting Guidance published by the U.S. Treasury identifies several steps in the reporting process:? Recipients gather and maintain required information such as counts of applicants and participants; amounts paid directly or indirectly to tenants, landlords, and utility/home energy providers; amounts paid to subrecipients and contractors; and administrative expenses.? Recipients will need to communicate with and gather required information from their subrecipients and contractors, if applicable.? After manually entering or uploading the report information, Recipients must review the information entered or submitted to the online reporting forms for any errors and completeness. Following completion of the report in Treasury?s portal, the Recipient?s designated Authorized Representative for Reporting must certify to the authenticity and accuracy of the information provided and formally submit the report to Treasury.SF-425, Federal Financial Report: As stated in the award terms and conditions of the award agreement, a final SF-425, Federal Financial Report, is due 90 days after the expiration of the award and should be submitted electronically. The awardee shall report program outlays and program income on the same accounting basis (i.e., cash or accrual) that it uses in its normal accounting system. When submitting a final SF-425, Federal Financial Report, the total matching contribution, if required, should be shown in the report. The final SF-425 must not show any unliquidated obligations. If the awardee still has valid obligations that remain unpaid when the report is due, it shall request an extension of time for submitting the report pursuant to paragraph (c) of this section; submit a provisional report (showing the unliquidated obligations) by the due date; and submit a final report when all obligations have been liquidated, but no later than the approved extension date. SF-425, Federal Financial Reports, must be submitted by all awardees, including Federal agencies and national laboratories.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:As the direct recipient of ERA funds, the Department of Community Affairs (DCA) is responsible for ensuring the timeliness and accuracy of report submissions. We noted that monthly and quarterly special reports and quarterly financial reports submitted during FY 2022 did not agree with supporting documentation.Context:We selected eight monthly special reports, four quarterly special reports, and two quarterly financial reports for testing and we noted that for 13 of 14 reports selected, amounts reported did not agree to supporting documentation. Specifically, we noted the following exceptions:? Four of four quarterly special reports submitted did not agree to supporting documentation.? Five of eight monthly special reports submitted were missing expenditures that were included in supporting documentation.? For two of eight monthly reports submitted, DCA was unable to provide supporting documentation for reported expenditures.? Two of two quarterly financial reports submitted did not agree to supporting documentation.We noted that the reports contained all required data elements, however, DCA was unable to provide supporting documentation that agreed with the information reported. We also noted that DCA used the same data used for the quarterly reports with their submission of the financial SF-425 reports.Cause:DCA?s procedures were not sufficient to ensure the accuracy of the reports submitted to the U.S. Treasury nor that it maintained documentation supporting the information reported. Internal controls did not prevent or detect the errors.Effect:Information reported to the U.S. Treasury may have been inaccurate since it did not agree to supporting documentation.Questioned costs:Undetermined.Recommendation:We recommend that DCA implement formal policies and procedures to verify the information reported and that reports are reviewed for accuracy before they are submitted to U.S. Treasury to ensure that reports filed are complete and accurate. We further recommend that DCA retains supporting documentation used when preparing reports, and that this documentation is available for audit.Views of responsible officials:U.S. Treasury?s COVID-19 Emergency Rental Assistance Program (ERA) was established in 2021 to support housing stability throughout the pandemic by providing assistance payments for renters facing eviction. The Department of Community Affairs (DCA) is a direct recipient of ERA funding for use in preventing evictions for over 70,000 families throughout the State of New Jersey.Since the rollout of the new ERA program back in 2021, the reporting requirements and guidance provided by U.S. Treasury to ERA recipients evolved with numerous changes and updates posted that also required DCA to change and update systems over time. As the programs continued to evolve so did DCA?s reporting process. U.S. Treasury initially required monthly reporting starting in April 2021, through which ERA recipients provided U.S. Treasury with very high-level counts of the numbers of households receiving assistance and the amounts of ERA funds distributed. The monthly reporting requirement was then discontinued after the June 30, 2022 submission and thereafter, U.S. Treasury shifted the ERA Reporting guidance to be focused primarily on the quarterly reporting requirements and also amended those reporting requirements going forward.When preparing monthly and quarterly reports, DCA?s data source used has always been the most reliable one at the time the report was due in order to ensure accuracy of information reported to U.S. Treasury. As previously stated, DCA?s systems evolved as needed in order to keep up with the constant changes in reporting requirements for the ERA program.? At the inception of the program, reporting was done from the primary Podio system that obligated and requested payments.? DCA then worked to build the necessary reports from the MRI system that generated ERA payments in order to trace payments back to checks issued ? representing distributions incurred.? Most recently DCA has been working to reconcile MRI with the State?s NJCFS accounting system to further validate the MRI data. Over time variances have been identified that affect reporting such as void and uncashed check actions.DCA recognizes the need to ensure supporting documentation used to prepare quarterly and other required reports for Treasury is captured and retained for audit purposes. DCA continues to build?a three-way reconciliation between the three primary systems to document explainable variances among the systems, such as timing differences, voids, returned items, etc. DCA has implemented a corrective action plan to enhance the availability of supporting documentation for ERA Treasury reporting as detailed in the State?s official corrective action plan.
Reference Number:2022-009Prior Year Finding:NoFederal Agency:U.S. Department of the TreasuryState Agency:Department of Community AffairsFederal Program:COVID-19 - Homeowner Assistance FundAssistance Listing Number:21.026Award Number and Year:HAF0019 (2021)Compliance Requirement:Reporting ? Federal Funding Accountability and Transparency Act (FFATA)Type of FindingMaterial Weakness in Internal Control Over Compliance, Material Non-complianceCriteria or specific requirement:Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements.The following key data elements must be reported: Subawardee Name and Unique Entity ID (UEI) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.)Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Subaward information was not reported timely to FSRS during FY 2022.Context:One subaward was issued by the Department of Community Affairs (Department) during FY 2022 which was selected for testing. The subaward was issued on 8/23/2021 and it was not reported to FSRS until 2/7/2022, or 130 days late.SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLECause:The Department?s internal controls were not sufficient to ensure that subawards were reported timely to FSRS during FY 2022.Effect:Subawards were not reported to FSRS in accordance with FFATA requirements.Questioned costs:None noted.Recommendation:We recommend that the Department develop internal controls and procedures to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements.Views of responsible officials:The Department of Community Affairs (DCA) has internal controls and procedures in place to ensure that required subawards are reported timely to FSRS in accordance with FFATA reporting requirements. The Homeowner Assistance Fund award received by DCA was unique in that it was planned and fully reallocated via Memorandum of Understanding (MOU) agreement to a DCA affiliate organization to administer on the State?s behalf. As a result, the DCA did not initially believe this single reallocation transaction was subject to FFATA reporting requirements. The Accountability Officer at the affiliate organization will be involved should another program and contractual arrangement of this type occur and will ensure that the FSRS reporting is done timely. No further subaward transactions are expected to be processed by DCA as the full allocation was disbursed to our affiliate organization upon receipt of the award and execution of the MOU.
Reference Number:2022-010Prior Year Finding:NoFederal Agency:U.S. Department of the TreasuryState Agency:Department of Community AffairsFederal Program:COVID-19 - Homeowner Assistance FundAssistance Listing Number:21.026Award Number and Year:HAF0019 (2021)Compliance Requirement:Subrecipient MonitoringType of FindingSignificant Deficiency in Internal Control over Compliance, Other MattersCriteria or specific requirement:Compliance ? Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.Required information includes:i. Subrecipient name (which must match the name associated with its unique entity identifier);ii. Subrecipient's unique entity identifier;iii. Federal Award Identification Number (FAIN);iv. Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency;v. Subaward Period of Performance Start and End Date;vi. Subaward Budget Period Start and End Date;vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient;viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation;ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity;x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA);xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity;xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement;xiii. Identification of whether the award is R&D; andxiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414.2 CFR section 200.332 also states that pass-through entities must:(d) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as:1) The subrecipient's prior experience with the same or similar subawards;2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program;3) Whether the subrecipient has new personnel or new or substantially changed systems;4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency).(e) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include:(1) Reviewing financial and performance reports required by the pass-through entity.(2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means.(3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521 Management decision.(f) Verify that every subrecipient is audited as required by Subpart F - Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501 Audit requirements.Control ? Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Community Affairs (Department) did not comply with subrecipient monitoring requirements for the program.Context:The Department issued one subaward under the program and it was noted that the subaward did not include all required Federal Award information, nor did the Department perform a risk assessment of the subrecipient or perform monitoring activities for the award.Questioned costs:None noted.Cause:The Department?s procedures and controls were not effective to ensure the subaward was issued in compliance with Federal requirements, nor that it performed a risk assessment or timely monitoring of subrecipient.Effect:Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance.Not conducting during the award monitoring may result in a failure of the Division to detect that its subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved.Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by Division personnel on a timely basis.Recommendation:The Department should review and enhance internal controls and procedures to ensure that all required information is included in all subawards, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed.Views of responsible officials:As recommended, the Department of Community Affairs (DCA) will review current procedures to ensure that all subaward information required by the federal Uniform Guidance is included in all subaward contracts and grant agreements. The DCA has also reviewed its current subrecipient monitoring procedures for standard subawards made by the agency and has determined that no internal control enhancements are required. The HAF award was a unique grant relationship for DCA in that the entire award was passed through to another New Jersey State government agency that is a direct affiliate of the Department. Monitoring procedures were determined based on the close working relationship with our affiliate organization and the fact that less than 1 percent of the grant award was expended through June 30, 2022. Current procedures included a risk assessment of the subrecipient and performance of the single audit desk review of the independent audit report. In addition, the Director of Audit, and the Executive Director of the subgrantee affiliate participate in weekly meetings where updates on the program status can be determined. DCA?s subrecipient monitoring plan also includes the hiring of an Integrity Monitor to oversee and monitor the use of the HAF funds as well as compliance with all HAF program reporting requirements. As program disbursement activity is continuing to increase with the HAF program(s) created more fully up and running, DCA is currently targeting the Integrity Monitor hire to take place sometime within the next three to six months.
Reference Number:2022-011Prior Year Finding:NoFederal Agency:U.S. Department of EducationState Agency:Department of CorrectionsFederal Program:Special Education Cluster IDEAAssistance Listing Number:84.027 and 84.173Award Number and Year:H027A200100 (7/1/2020 ? 9/30/2021), H027A200100-20A (7/1/2020 ? 9/30/2021), H027A210100 (7/1/2021 ? 9/30/2022), H027A2100100-21A (7/1/2021 ? 9/30/2022), H027X210100 (7/1/2021 ? 9/30/2022), H173A200114 (7/1/2020 ? 9/30/2021), H173A210114 (7/1/2021 ? 9/30/2022), H173X210114 (7/1/2021 ? 9/30/2021)Compliance Requirement:Allowable Costs/Cost Principles ? Time and Effort ReportingType of Finding:Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance ? Per 2 CFR ? 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.Per 2 CFR ? 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated,? Be incorporated into the official records of the non-Federal entity,? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities,? Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy,? Comply with the established accounting policies and practices of the non-Federal entity,? Support the distribution of the employee's salary or wages among specific activities or costobjectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.Control ? Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Corrections (Department) did not maintain adequate support to validate actual payroll expenses charged to the program. An employee?s timesheet was not approved by the supervisor on a timely basis.Context:The Department was unable to provide documentation that one of forty employee timesheets selected for testing had been approved by the supervisor on a timely basis.Questioned costs:None noted.Cause:Controls were not operating effectively to ensure that time and effort reporting was performed in accordance with federal requirements.Effect:There is an increased risk of charging unallowed payroll costs to the program.Recommendation:The Department should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Department should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program.Views of responsible officials:The Department of Corrections (DOC) held a meeting on March 22, 2023 with the Supervisors of Education where the importance of reviewing and approving all timesheets was reinforced. Staff were also informed and reminded of progressive discipline for future instances of timesheet approval omissions. DOC also plans to distribute a memorandum to all Supervisors and Assistant Supervisors of Education in an effort to ensure that proper controls are implemented for timely supervisory review and approvals of timesheets as required. Supervisors were also instructed to substantiate via email that timesheet approval, in their absence, will be approved by DOC Administration at their facility.
Reference Number:2022-011Prior Year Finding:NoFederal Agency:U.S. Department of EducationState Agency:Department of CorrectionsFederal Program:Special Education Cluster IDEAAssistance Listing Number:84.027 and 84.173Award Number and Year:H027A200100 (7/1/2020 ? 9/30/2021), H027A200100-20A (7/1/2020 ? 9/30/2021), H027A210100 (7/1/2021 ? 9/30/2022), H027A2100100-21A (7/1/2021 ? 9/30/2022), H027X210100 (7/1/2021 ? 9/30/2022), H173A200114 (7/1/2020 ? 9/30/2021), H173A210114 (7/1/2021 ? 9/30/2022), H173X210114 (7/1/2021 ? 9/30/2021)Compliance Requirement:Allowable Costs/Cost Principles ? Time and Effort ReportingType of Finding:Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance ? Per 2 CFR ? 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.Per 2 CFR ? 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated,? Be incorporated into the official records of the non-Federal entity,? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities,? Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy,? Comply with the established accounting policies and practices of the non-Federal entity,? Support the distribution of the employee's salary or wages among specific activities or costobjectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.Control ? Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Corrections (Department) did not maintain adequate support to validate actual payroll expenses charged to the program. An employee?s timesheet was not approved by the supervisor on a timely basis.Context:The Department was unable to provide documentation that one of forty employee timesheets selected for testing had been approved by the supervisor on a timely basis.Questioned costs:None noted.Cause:Controls were not operating effectively to ensure that time and effort reporting was performed in accordance with federal requirements.Effect:There is an increased risk of charging unallowed payroll costs to the program.Recommendation:The Department should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Department should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program.Views of responsible officials:The Department of Corrections (DOC) held a meeting on March 22, 2023 with the Supervisors of Education where the importance of reviewing and approving all timesheets was reinforced. Staff were also informed and reminded of progressive discipline for future instances of timesheet approval omissions. DOC also plans to distribute a memorandum to all Supervisors and Assistant Supervisors of Education in an effort to ensure that proper controls are implemented for timely supervisory review and approvals of timesheets as required. Supervisors were also instructed to substantiate via email that timesheet approval, in their absence, will be approved by DOC Administration at their facility.
Reference Number:2022-011Prior Year Finding:NoFederal Agency:U.S. Department of EducationState Agency:Department of CorrectionsFederal Program:Special Education Cluster IDEAAssistance Listing Number:84.027 and 84.173Award Number and Year:H027A200100 (7/1/2020 ? 9/30/2021), H027A200100-20A (7/1/2020 ? 9/30/2021), H027A210100 (7/1/2021 ? 9/30/2022), H027A2100100-21A (7/1/2021 ? 9/30/2022), H027X210100 (7/1/2021 ? 9/30/2022), H173A200114 (7/1/2020 ? 9/30/2021), H173A210114 (7/1/2021 ? 9/30/2022), H173X210114 (7/1/2021 ? 9/30/2021)Compliance Requirement:Allowable Costs/Cost Principles ? Time and Effort ReportingType of Finding:Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance ? Per 2 CFR ? 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.Per 2 CFR ? 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated,? Be incorporated into the official records of the non-Federal entity,? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities,? Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy,? Comply with the established accounting policies and practices of the non-Federal entity,? Support the distribution of the employee's salary or wages among specific activities or costobjectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.Control ? Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Corrections (Department) did not maintain adequate support to validate actual payroll expenses charged to the program. An employee?s timesheet was not approved by the supervisor on a timely basis.Context:The Department was unable to provide documentation that one of forty employee timesheets selected for testing had been approved by the supervisor on a timely basis.Questioned costs:None noted.Cause:Controls were not operating effectively to ensure that time and effort reporting was performed in accordance with federal requirements.Effect:There is an increased risk of charging unallowed payroll costs to the program.Recommendation:The Department should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Department should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program.Views of responsible officials:The Department of Corrections (DOC) held a meeting on March 22, 2023 with the Supervisors of Education where the importance of reviewing and approving all timesheets was reinforced. Staff were also informed and reminded of progressive discipline for future instances of timesheet approval omissions. DOC also plans to distribute a memorandum to all Supervisors and Assistant Supervisors of Education in an effort to ensure that proper controls are implemented for timely supervisory review and approvals of timesheets as required. Supervisors were also instructed to substantiate via email that timesheet approval, in their absence, will be approved by DOC Administration at their facility.
Reference Number:2022-011Prior Year Finding:NoFederal Agency:U.S. Department of EducationState Agency:Department of CorrectionsFederal Program:Special Education Cluster IDEAAssistance Listing Number:84.027 and 84.173Award Number and Year:H027A200100 (7/1/2020 ? 9/30/2021), H027A200100-20A (7/1/2020 ? 9/30/2021), H027A210100 (7/1/2021 ? 9/30/2022), H027A2100100-21A (7/1/2021 ? 9/30/2022), H027X210100 (7/1/2021 ? 9/30/2022), H173A200114 (7/1/2020 ? 9/30/2021), H173A210114 (7/1/2021 ? 9/30/2022), H173X210114 (7/1/2021 ? 9/30/2021)Compliance Requirement:Allowable Costs/Cost Principles ? Time and Effort ReportingType of Finding:Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance ? Per 2 CFR ? 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.Per 2 CFR ? 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated,? Be incorporated into the official records of the non-Federal entity,? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities,? Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy,? Comply with the established accounting policies and practices of the non-Federal entity,? Support the distribution of the employee's salary or wages among specific activities or costobjectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.Control ? Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Corrections (Department) did not maintain adequate support to validate actual payroll expenses charged to the program. An employee?s timesheet was not approved by the supervisor on a timely basis.Context:The Department was unable to provide documentation that one of forty employee timesheets selected for testing had been approved by the supervisor on a timely basis.Questioned costs:None noted.Cause:Controls were not operating effectively to ensure that time and effort reporting was performed in accordance with federal requirements.Effect:There is an increased risk of charging unallowed payroll costs to the program.Recommendation:The Department should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Department should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program.Views of responsible officials:The Department of Corrections (DOC) held a meeting on March 22, 2023 with the Supervisors of Education where the importance of reviewing and approving all timesheets was reinforced. Staff were also informed and reminded of progressive discipline for future instances of timesheet approval omissions. DOC also plans to distribute a memorandum to all Supervisors and Assistant Supervisors of Education in an effort to ensure that proper controls are implemented for timely supervisory review and approvals of timesheets as required. Supervisors were also instructed to substantiate via email that timesheet approval, in their absence, will be approved by DOC Administration at their facility.
Reference Number:2022-012Prior Year Finding:2021-015Federal Agency:U.S. Department of Health and Human ServicesState Agency:Department of Human ServicesFederal Program:Aging Cluster and COVID-19 Aging ClusterAssistance Listing Number:93.044, 93.045, 93.053Award Number and Year:2001NJCMC2-00 (3/20/2020 ? 9/30/2022)2101NJVAC5-00 (4/1/2022 ? 9/30/2022)2001NJHDC2-00 (3/20/2020 ? 9/30/2022)2101NJOASS-00 (10/1/2020 ? 9/30/2022)2101NJOASS-01 (10/1/2020 ? 9/30/2022)2101NJOANS-00 (10/1/2020 ? 9/30/2022)2101NJHDC5-00 (12/27/2020 ? 9/30/2022)2101NJSSC6-00 (4/1/2022 ? 9/30/2024)2001NJOASS-03 (10/1/2019 ? 9/30/2022)2001NJOANS-04 (10/1/2019 ? 9/30/2022)2201NJOASS-02 (10/1/2021 ? 9/30/2023)2201NJOACM-02 (10/1/2021 ? 9/30/2023)2201NJOAHD-02 (10/1/2021-9/30/2023)2201NJOAPH-02 (10/1/2021-9/30/2023)2201NJOAFC-02 (10/1/2021-9/30/2023)Compliance Requirement:Reporting ? Federal Funding Accountability and Transparency Act (FFATA)Type of FindingMaterial Weakness in Internal Control Over Compliance, Material Non-complianceCriteria or specific requirement:Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements.The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.)Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Subaward information was not reported to FSRS during FY 2022.Context:Zero of six subrecipients selected for testing were reported to FSRS during FY 2022. Total subawards tested were $35,266,155, and $0 was reported as required by FFATA requirements.SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLECause:The Department was unaware of FFATA reporting requirements and did not report subaward information to FSRS during FY 2022.Effect:Subawards were not reported to FSRS in accordance with FFATA requirements.Questioned costs:None noted.Recommendation:We recommend that the Department develop internal controls and procedures to ensure that FFATA reporting requirements are met. We further recommend the Department develop controls and procedures to ensure that all required subawards are reported accurately and timely to FSRS no later than the end of the month following the month of issuance.Views of responsible officials:The Department of Human Services, Division of Aging Services (DoAS) continues to work towards attaining full compliance with Federal Funding Accountability and Transparency Act (FFATA) requirements. The DoAS continues to consult with the Department and/or other DHS Division fiscal leadership to finalize the FFATA procedures. These procedures shall include creating a list of all active first-tier subawards of federal funds DoAS has issued at $30,000 or more. The list will include all the data fields required for FFATA reporting. DoAS grants management members will ensure each of the identified subawards is entered on the Federal Subaward Reporting System (FSRS) website. DoASwill also revise internal procedures to ensure all future subawards of $30,000 or more are entered on FSRS within 30 days of award.
Reference Number:2022-012Prior Year Finding:2021-015Federal Agency:U.S. Department of Health and Human ServicesState Agency:Department of Human ServicesFederal Program:Aging Cluster and COVID-19 Aging ClusterAssistance Listing Number:93.044, 93.045, 93.053Award Number and Year:2001NJCMC2-00 (3/20/2020 ? 9/30/2022)2101NJVAC5-00 (4/1/2022 ? 9/30/2022)2001NJHDC2-00 (3/20/2020 ? 9/30/2022)2101NJOASS-00 (10/1/2020 ? 9/30/2022)2101NJOASS-01 (10/1/2020 ? 9/30/2022)2101NJOANS-00 (10/1/2020 ? 9/30/2022)2101NJHDC5-00 (12/27/2020 ? 9/30/2022)2101NJSSC6-00 (4/1/2022 ? 9/30/2024)2001NJOASS-03 (10/1/2019 ? 9/30/2022)2001NJOANS-04 (10/1/2019 ? 9/30/2022)2201NJOASS-02 (10/1/2021 ? 9/30/2023)2201NJOACM-02 (10/1/2021 ? 9/30/2023)2201NJOAHD-02 (10/1/2021-9/30/2023)2201NJOAPH-02 (10/1/2021-9/30/2023)2201NJOAFC-02 (10/1/2021-9/30/2023)Compliance Requirement:Reporting ? Federal Funding Accountability and Transparency Act (FFATA)Type of FindingMaterial Weakness in Internal Control Over Compliance, Material Non-complianceCriteria or specific requirement:Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements.The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.)Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Subaward information was not reported to FSRS during FY 2022.Context:Zero of six subrecipients selected for testing were reported to FSRS during FY 2022. Total subawards tested were $35,266,155, and $0 was reported as required by FFATA requirements.SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLECause:The Department was unaware of FFATA reporting requirements and did not report subaward information to FSRS during FY 2022.Effect:Subawards were not reported to FSRS in accordance with FFATA requirements.Questioned costs:None noted.Recommendation:We recommend that the Department develop internal controls and procedures to ensure that FFATA reporting requirements are met. We further recommend the Department develop controls and procedures to ensure that all required subawards are reported accurately and timely to FSRS no later than the end of the month following the month of issuance.Views of responsible officials:The Department of Human Services, Division of Aging Services (DoAS) continues to work towards attaining full compliance with Federal Funding Accountability and Transparency Act (FFATA) requirements. The DoAS continues to consult with the Department and/or other DHS Division fiscal leadership to finalize the FFATA procedures. These procedures shall include creating a list of all active first-tier subawards of federal funds DoAS has issued at $30,000 or more. The list will include all the data fields required for FFATA reporting. DoAS grants management members will ensure each of the identified subawards is entered on the Federal Subaward Reporting System (FSRS) website. DoASwill also revise internal procedures to ensure all future subawards of $30,000 or more are entered on FSRS within 30 days of award.
Reference Number:2022-012Prior Year Finding:2021-015Federal Agency:U.S. Department of Health and Human ServicesState Agency:Department of Human ServicesFederal Program:Aging Cluster and COVID-19 Aging ClusterAssistance Listing Number:93.044, 93.045, 93.053Award Number and Year:2001NJCMC2-00 (3/20/2020 ? 9/30/2022)2101NJVAC5-00 (4/1/2022 ? 9/30/2022)2001NJHDC2-00 (3/20/2020 ? 9/30/2022)2101NJOASS-00 (10/1/2020 ? 9/30/2022)2101NJOASS-01 (10/1/2020 ? 9/30/2022)2101NJOANS-00 (10/1/2020 ? 9/30/2022)2101NJHDC5-00 (12/27/2020 ? 9/30/2022)2101NJSSC6-00 (4/1/2022 ? 9/30/2024)2001NJOASS-03 (10/1/2019 ? 9/30/2022)2001NJOANS-04 (10/1/2019 ? 9/30/2022)2201NJOASS-02 (10/1/2021 ? 9/30/2023)2201NJOACM-02 (10/1/2021 ? 9/30/2023)2201NJOAHD-02 (10/1/2021-9/30/2023)2201NJOAPH-02 (10/1/2021-9/30/2023)2201NJOAFC-02 (10/1/2021-9/30/2023)Compliance Requirement:Reporting ? Federal Funding Accountability and Transparency Act (FFATA)Type of FindingMaterial Weakness in Internal Control Over Compliance, Material Non-complianceCriteria or specific requirement:Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements.The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.)Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Subaward information was not reported to FSRS during FY 2022.Context:Zero of six subrecipients selected for testing were reported to FSRS during FY 2022. Total subawards tested were $35,266,155, and $0 was reported as required by FFATA requirements.SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLECause:The Department was unaware of FFATA reporting requirements and did not report subaward information to FSRS during FY 2022.Effect:Subawards were not reported to FSRS in accordance with FFATA requirements.Questioned costs:None noted.Recommendation:We recommend that the Department develop internal controls and procedures to ensure that FFATA reporting requirements are met. We further recommend the Department develop controls and procedures to ensure that all required subawards are reported accurately and timely to FSRS no later than the end of the month following the month of issuance.Views of responsible officials:The Department of Human Services, Division of Aging Services (DoAS) continues to work towards attaining full compliance with Federal Funding Accountability and Transparency Act (FFATA) requirements. The DoAS continues to consult with the Department and/or other DHS Division fiscal leadership to finalize the FFATA procedures. These procedures shall include creating a list of all active first-tier subawards of federal funds DoAS has issued at $30,000 or more. The list will include all the data fields required for FFATA reporting. DoAS grants management members will ensure each of the identified subawards is entered on the Federal Subaward Reporting System (FSRS) website. DoASwill also revise internal procedures to ensure all future subawards of $30,000 or more are entered on FSRS within 30 days of award.
Reference Number:2022-012Prior Year Finding:2021-015Federal Agency:U.S. Department of Health and Human ServicesState Agency:Department of Human ServicesFederal Program:Aging Cluster and COVID-19 Aging ClusterAssistance Listing Number:93.044, 93.045, 93.053Award Number and Year:2001NJCMC2-00 (3/20/2020 ? 9/30/2022)2101NJVAC5-00 (4/1/2022 ? 9/30/2022)2001NJHDC2-00 (3/20/2020 ? 9/30/2022)2101NJOASS-00 (10/1/2020 ? 9/30/2022)2101NJOASS-01 (10/1/2020 ? 9/30/2022)2101NJOANS-00 (10/1/2020 ? 9/30/2022)2101NJHDC5-00 (12/27/2020 ? 9/30/2022)2101NJSSC6-00 (4/1/2022 ? 9/30/2024)2001NJOASS-03 (10/1/2019 ? 9/30/2022)2001NJOANS-04 (10/1/2019 ? 9/30/2022)2201NJOASS-02 (10/1/2021 ? 9/30/2023)2201NJOACM-02 (10/1/2021 ? 9/30/2023)2201NJOAHD-02 (10/1/2021-9/30/2023)2201NJOAPH-02 (10/1/2021-9/30/2023)2201NJOAFC-02 (10/1/2021-9/30/2023)Compliance Requirement:Reporting ? Federal Funding Accountability and Transparency Act (FFATA)Type of FindingMaterial Weakness in Internal Control Over Compliance, Material Non-complianceCriteria or specific requirement:Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements.The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.)Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Subaward information was not reported to FSRS during FY 2022.Context:Zero of six subrecipients selected for testing were reported to FSRS during FY 2022. Total subawards tested were $35,266,155, and $0 was reported as required by FFATA requirements.SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLECause:The Department was unaware of FFATA reporting requirements and did not report subaward information to FSRS during FY 2022.Effect:Subawards were not reported to FSRS in accordance with FFATA requirements.Questioned costs:None noted.Recommendation:We recommend that the Department develop internal controls and procedures to ensure that FFATA reporting requirements are met. We further recommend the Department develop controls and procedures to ensure that all required subawards are reported accurately and timely to FSRS no later than the end of the month following the month of issuance.Views of responsible officials:The Department of Human Services, Division of Aging Services (DoAS) continues to work towards attaining full compliance with Federal Funding Accountability and Transparency Act (FFATA) requirements. The DoAS continues to consult with the Department and/or other DHS Division fiscal leadership to finalize the FFATA procedures. These procedures shall include creating a list of all active first-tier subawards of federal funds DoAS has issued at $30,000 or more. The list will include all the data fields required for FFATA reporting. DoAS grants management members will ensure each of the identified subawards is entered on the Federal Subaward Reporting System (FSRS) website. DoASwill also revise internal procedures to ensure all future subawards of $30,000 or more are entered on FSRS within 30 days of award.
Reference Number:2022-012Prior Year Finding:2021-015Federal Agency:U.S. Department of Health and Human ServicesState Agency:Department of Human ServicesFederal Program:Aging Cluster and COVID-19 Aging ClusterAssistance Listing Number:93.044, 93.045, 93.053Award Number and Year:2001NJCMC2-00 (3/20/2020 ? 9/30/2022)2101NJVAC5-00 (4/1/2022 ? 9/30/2022)2001NJHDC2-00 (3/20/2020 ? 9/30/2022)2101NJOASS-00 (10/1/2020 ? 9/30/2022)2101NJOASS-01 (10/1/2020 ? 9/30/2022)2101NJOANS-00 (10/1/2020 ? 9/30/2022)2101NJHDC5-00 (12/27/2020 ? 9/30/2022)2101NJSSC6-00 (4/1/2022 ? 9/30/2024)2001NJOASS-03 (10/1/2019 ? 9/30/2022)2001NJOANS-04 (10/1/2019 ? 9/30/2022)2201NJOASS-02 (10/1/2021 ? 9/30/2023)2201NJOACM-02 (10/1/2021 ? 9/30/2023)2201NJOAHD-02 (10/1/2021-9/30/2023)2201NJOAPH-02 (10/1/2021-9/30/2023)2201NJOAFC-02 (10/1/2021-9/30/2023)Compliance Requirement:Reporting ? Federal Funding Accountability and Transparency Act (FFATA)Type of FindingMaterial Weakness in Internal Control Over Compliance, Material Non-complianceCriteria or specific requirement:Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements.The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.)Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Subaward information was not reported to FSRS during FY 2022.Context:Zero of six subrecipients selected for testing were reported to FSRS during FY 2022. Total subawards tested were $35,266,155, and $0 was reported as required by FFATA requirements.SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLECause:The Department was unaware of FFATA reporting requirements and did not report subaward information to FSRS during FY 2022.Effect:Subawards were not reported to FSRS in accordance with FFATA requirements.Questioned costs:None noted.Recommendation:We recommend that the Department develop internal controls and procedures to ensure that FFATA reporting requirements are met. We further recommend the Department develop controls and procedures to ensure that all required subawards are reported accurately and timely to FSRS no later than the end of the month following the month of issuance.Views of responsible officials:The Department of Human Services, Division of Aging Services (DoAS) continues to work towards attaining full compliance with Federal Funding Accountability and Transparency Act (FFATA) requirements. The DoAS continues to consult with the Department and/or other DHS Division fiscal leadership to finalize the FFATA procedures. These procedures shall include creating a list of all active first-tier subawards of federal funds DoAS has issued at $30,000 or more. The list will include all the data fields required for FFATA reporting. DoAS grants management members will ensure each of the identified subawards is entered on the Federal Subaward Reporting System (FSRS) website. DoASwill also revise internal procedures to ensure all future subawards of $30,000 or more are entered on FSRS within 30 days of award.