Eligibility U.S. Department of Health and Human Services Community Service Block Grant – ALN #93.569Criterion:Per 2 CFR 200.303, 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 terms and conditions of the Federal Award.The Organization is responsible for ensuring that a participant is eligible to receive services under the CSBG program. The Organization requires management review of participant files to ensure that eligibility procedures have been performed during the intake process to ensure each participant is eligible. Condition:During our review of 25 eligible participant files, 18 out of 25 participant files did not contain evidence of management review prior to CSBG program benefits being provided.Cause and Effect:Management has a process in place to ensure that effective internal controls related to CSBG Eligibility requirements are properly implemented. The internal controls the Organization has in place for the CSBG eligibility determination process were not utilized. Therefore, intake forms and other relevant documentation within CSBG participant files were not properly approved by management in accordance with 2 CFR part 200, subpart D. Recommendation: We recommend that management enhance the design of its control activities to ensure that CSBG participant files are adequately maintained, and strengthen controls surrounding management review of participant files during the intake process to ensure individuals receiving services are eligible for benefits.View of Responsible Officials:The Organization agrees with this finding and has developed a corrective action plan to address.
Eligibility U.S. Department of Health and Human Services Community Service Block Grant – ALN #93.569Criterion:Per 2 CFR 200.303, 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 terms and conditions of the Federal Award.The Organization is responsible for ensuring that a participant is eligible to receive services under the CSBG program. The Organization requires management review of participant files to ensure that eligibility procedures have been performed during the intake process to ensure each participant is eligible. Condition:During our review of 25 eligible participant files, 18 out of 25 participant files did not contain evidence of management review prior to CSBG program benefits being provided.Cause and Effect:Management has a process in place to ensure that effective internal controls related to CSBG Eligibility requirements are properly implemented. The internal controls the Organization has in place for the CSBG eligibility determination process were not utilized. Therefore, intake forms and other relevant documentation within CSBG participant files were not properly approved by management in accordance with 2 CFR part 200, subpart D. Recommendation: We recommend that management enhance the design of its control activities to ensure that CSBG participant files are adequately maintained, and strengthen controls surrounding management review of participant files during the intake process to ensure individuals receiving services are eligible for benefits.View of Responsible Officials:The Organization agrees with this finding and has developed a corrective action plan to address.
Finding Title: Lack of Documented Evidence of Review Process for Reports Submitted to HRSA Federal Agency: U.S. Department of Health and Human Services (HHS) - Health Resources and Services Administration (HRSA) Federal Program: COVID-19 Provider Relief Fund Assistance Listing Number: 93.498 Award Year: January 1, 2022 to June 30, 2022 Compliance Requirement: Reporting Questioned Costs: N/A Type of Finding: A Significant Deficiency in Internal Control Over Compliance Criteria: The Uniform Guidance Compliance Supplement (2 CFR § 200.303) requires agencies to establish and maintain effective internal controls over federal awards to ensure compliance with statutes, regulations, and the terms of federal awards. Documented evidence of controls, such as review and approval processes, is critical for demonstrating compliance with federal reporting requirements. Condition: During testing of compliance controls, we noted that the Agency failed to provide documented evidence supporting the review and approval process for reports submitted to the Health Resources and Services Administration (HRSA). Management could not produce traceable records or evidence demonstrating that reports were reviewed for accuracy and completeness prior to submission. Cause: The deficiency arose from a lack of formalized processes and procedures requiring the documentation of review and approval steps for federal grant reporting. Contributing factors included inadequate oversight and insufficient training on federal grant compliance requirements. Effect: The absence of documented evidence of a review process increases the risk of errors or omissions in reports submitted to HRSA. This deficiency could result in non-compliance with federal reporting requirements, potentially jeopardizing the Agency's ability to demonstrate appropriate use of Provider Relief Fund (PRF) grant funds. Context: The Provider Relief Fund (PRF), established under the CARES Act, supports healthcare providers affected by the COVID-19 pandemic. Recipients of PRF funds are required to submit detailed reports to HRSA, ensuring accountability and transparency in the allocation of federal resources. A documented review process is essential to ensure that submitted reports accurately reflect the use of grant funds in compliance with federal requirements. Recommendation: We recommend that the Agency: - Develop and implement formalized procedures for the review and approval of federal grant reports before submission to HRSA. - Maintain traceable audit evidence, such as documented review checklists, signed approvals, and timestamps, to demonstrate compliance with federal reporting requirements. - Provide training to staff involved in the preparation and review of federal grant reports to ensure understanding of compliance requirements and the importance of documentation.
Department of Health and Human Services Federal Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year - Period 2 TIN #736060815 Reporting Material Weakness in Internal Control Over Compliance and Material Noncompliance Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Authority selected Option 1, as defined by HRSA, to calculate lost revenue. This option consists of reporting actual revenues from relevant quarters in the period of availability with the system calculating the lost revenues because of declines. The fiscal year 2021 single audit identified unallowable expenses totaling $263,861. The Company utilized excess lost revenues at the time to cover this difference. To capture the use of these lost revenues from Period 1, the Authority should have used Option 3, as defined by HRSA, to calculate and report lost revenues. Within that calculation, lost revenues could then be reduced by the $263,861. Cause: The Authority's Period 2 report to HRSA was filed prior to the completion of the 2021 single audit and identification of these unallowable expenses. Effect: The reporting to HRSA for Period 2 was considered incorrect. The Authority did not reduce lost revenues by amounts used in the prior period on unallowable expenses. While the effects of the report errors did not result in unallowable lost revenues during Period 2, errors to amounts reported for lost revenues could result in unallowable costs. Questioned Costs: None reported. Context/Sampling: All key line items on the Period 2 report to HRSA were tested. Repeat Finding from Prior Years: No. Recommendation: We recommend the Authority report on lost revenues for any future reporting to HRSA utilizing Option 3 in order to show the use of the unallowable expenses from Period 1. Views of Responsible Officials: Management agrees with the finding.
Department of Health and Human Services Federal Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year -Period 2 TIN #736060815 Reporting Material Weakness in Internal Control Over Compliance and Noncompliance Deemed Not Material Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Authority tracked patient care revenues internally within a spreadsheet. The calculations of revenue by payor within the spreadsheet and included on the Period 2 report to HRSA, which were utilized to calculate lost revenues, contained errors. Cause: The Authority’s internal controls in place to review the lost revenue calculation prior to finalization of the HRSA Period 2 submission did not identify errors in the calculation. Additionally, the review and approval of the report submitted to the Health Resources and Services Administration (HRSA) for Period 2 was not performed by someone other than the preparer, resulting in the errors in patient revenue by payor not being detected. Effect: The reporting to HRSA for Period 2 contained errors in patient care revenue by payor, which are considered key line items in that report. While the result of the errors did not impact lost revenues calculated, there is a potential for similar errors to impact the lost revenue calculation. In addition, the lack of review of the report increases the possibility that ineligible expenditures may be claimed under the program and the report may not be accurately completed. Questioned Costs: None. While there were errors in patient care revenues by payors for certain key line items, the errors did not impact the calculation of lost revenues. Context: All key line items related to the calculation of lost revenues based on an Option 1 calculation, as defined by HRSA, were tested. Errors were identified in 8 key line items specifically related to patient care revenues by payor for two separate quarters. The errors did not impact the total revenue reported for any quarter. Repeat Finding from Prior Years: No Recommendation: We recommend management implement policies and procedures to ensure a complete revenue of supporting documentation and any reporting to a federal agency prior to submission by an individual separate from the preparer. Views of Responsible Officials: Management agrees with the finding.
Finding 2022-015 – Lack of Internal Controls Over Major Federal Program – Coronavirus State and Local Fiscal Recovery Funds PASS THROUGH GRANTOR: Direct Grant FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) FEDERAL AWARD NUMBER: SLFRP3720 FEDERAL AWARD YEAR: 2022 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Procurement and Suspension and Debarment; Reporting QUESTIONED COSTS: $-0- Condition: During the process of documenting the County’s internal controls regarding federal disbursements, we noted that Muskogee County has not established procedures to ensure compliance with the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; and Period of Performance, Procurement and Suspension and Debarment, and Reporting. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with federal grant requirements. Effect of Condition: This condition could result in noncompliance to grant requirements and could lead to a loss of federal funds to the County. Recommendation: OSAI recommends that the County gain an understanding of requirements for these programs and implement a system of internal control procedures to ensure compliance with grant requirements. Management Response: Chairman of the Board of County Commissioners: Muskogee County has hired an internal grant administrator to assist in keeping the county compliant with all local, state, and federal requirements. Efforts will be made going forward to ensure that all grant funds are properly expended. Criteria: 2 CFR § 200.303 Internal Controls (a) reads as follows: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Further, accountability and stewardship should be overall goals in management’s accounting of federal funds. Internal controls should be designed to monitor compliance with laws and regulations pertaining to grant contracts.
Finding 2022-013 - Noncompliance Over Reporting – Coronavirus State and Local Fiscal Recovery Funds PASS THROUGH GRANTOR: Direct Grant FEDERAL AGENCY: United States Department of the Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) FEDERAL AWARD NUMBER: SLFRP3720 FEDERAL AWARD YEAR: 2022 CONTROL CATEGORY: Reporting QUESTIONED COSTS: $0 Condition: During the process of documenting the County’s internal controls regarding federal reporting process, we noted that the County has not established procedures to ensure compliance with reporting requirement. Furthermore, while performing a test over the reporting requirement, we noted the following: • Interim report was not submitted. • Variances between expenditures reported on the quarterly reports and the County’s expenditure data: o Quarterly reports during the period of March through December 2021 expenditure amounts were more than County’s the expenditure data by $124,984. o Quarterly report Q1 2022 expenditure amount was more than the County’s expenditure data by $1,140,410. o Quarterly report Q2 2022 expenditure amount was less than the County’s expenditure data by $39,146. Cause of Condition: Policies and procedures have not been designed and implemented to ensure compliance of reporting compliance requirements. Effect of Condition: This condition resulted in noncompliance with grant requirements. Recommendation: OSAI recommends the County comply with federal laws and regulations and grant agreements by submitting required reports to the U.S. Department of the Treasury timely. In addition, OSAI recommends the County design and implement a system of internal controls to ensure the accuracy and completeness of information submitted. Management Response: Chairman of the Board of County Commissioners: Muskogee County has hired an internal grant administrator to assist in keeping the county compliant with all local, state, and federal requirements. Efforts will be made going forward to ensure that all grant funds are properly expended and properly reported. Criteria: GAO Standards – Section 2 – Establishing an Effective Internal Control System – OV2.23 states in part: Objectives of an Entity – Compliance Objectives Management conducts activities in accordance with applicable laws and regulations. As part of specifying compliance objectives, the entity determines which laws and regulations apply to the entity. Management is expected to set objectives that incorporate these requirements. 2 CFR § 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance and Reporting Guide – State and Local Fiscal Recovery Funds – Version 5.2 also states in part: States, U.S. territories, metropolitan cities, counties, and Tribal governments were required to submit a one-time interim report with expenditures7 by Expenditure Category covering the period from March 3rd to July 31, 2021, by August 31, 2021 or sixty (60) days after first receiving funding if the recipient’s date of award was between July 15, 2021 and October 15, 2021.
2022-004 Program Name/CFDA Title: Community Facilities Loans and Grants Federal Assistance Listing Number: 10.766 Federal Agency: U.S. Department of Agriculture Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions Condition: During our testing we noted the Hospital's debt reserve account was withdrawn to a level below the required minimum balance without proper authroization from the USDA. Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the fedreal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Cause: The Hospital did not have an adequate interal control policy in place to ensure review and approval over activity related to the reserve fund. Effect: The lack of adequate policies governing review increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported Prior Year Finding: No Recommendation: We recommend the Hospital enhance internal control policies to ensure a formal review over the reserve fund in comparison to the required minimum reserve balance be completed by an indvidiaual separate from the preparer. Views of Responsible Official: Management agrees with the finding and has committed the resources giving rise to the finding.
Finding 2022-012 – Lack of County-Wide Controls Over Major Federal Program – Coronavirus State and Local Fiscal Recovery Funds (Repeat Finding 2021-011) FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds FEDERAL AWARD NUMBER: SLFRP4587 FEDERAL AWARD YEAR: 2022 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Costs Principles; Procurement and Suspension and Debarment; Reporting; and Subrecipient Monitoring QUESTIONED COSTS: - $0 - Condition: Through the process of gaining an understanding of the County’s internal control structure for federal programs, it was noted that county-wide internal controls regarding Control Environment, Risk Assessment, Information and Communication, and Monitoring have not been designed. The following deficiencies were noted: • The BOCC is aware there are compliance supplement requirements; however, they are not aware of the specifics of the requirements and there is no one assigned to keep up with the compliance requirements. • There is no evidence federal expenditures are presented to the BOCC in an open meeting prior to submission to the awarding agency. • The risks of incorrect financial reporting, resulting from fraud or error, for the Schedule of Expenditures of Federal Awards (SEFA) are not addressed verbally or in written communication. • The County is relying on the Clerk and Treasurer to ensure the accuracy of the SEFA. • The individual submitting reports to the U.S. Department of the Treasury is using credentials assigned to someone else. Cause of Condition: Policies and procedures have not been designed and implemented to ensure the County complies with grant requirements. Effect of Condition: Without an adequate system of county-wide controls, there is greater risk of a breakdown in control activities which could result in unrecorded transactions, undetected errors, misappropriation of funds, and noncompliance with federal grant requirements. Recommendation: OSAI recommends that the County implement a system of internal controls to ensure compliance with grant requirements. Management Response: District 1 County Commissioner: Not by way of excuse, but truly in response, the Federal programs associated with the COVID response were unnecessarily arduous and created confusion at all levels of government. While the monetary response was accepted, the premise of these programs was nothing more than an administrative shell game. From the outset of the response, guidance was termed as “interim”, then “final Interim” and finally, “final” (redundancy intentional). The intent of our national level leadership became more apparent as these programs progressed with each iteration of programming being reliant on returned funds from the previous. Without grandstanding, I will simply say that no entity, regardless of their planning with these programs, will be found as fully compliant. As these programs have a sunset in the near term, I suspect these findings will disappear. District 2 County Commissioner: I was not in office the year audited, but I will work with other elected officials to implement a system of internal controls to ensure compliance with grants requirements. District 3 County Commissioner: The elected officials will work together to implement a system of internal controls to ensure compliance with grant requirements. Criteria: The GAO Standards – Section 1 – Fundamental Concepts of Internal Control – OV1.01 states in part: Definition of Internal Control Internal control is a process effected by an entity’s oversight body, management, and other personnel that provides reasonable assurance that the objectives of an entity will be achieved. Additionally, GAO Standards – Section 2 – Establishing an Effective Internal Control System – OV2.04 states in part: Components, Principles, and Attributes Control Environment - The foundation for an internal control system. It provides the discipline and structure to help an entity achieve its objectives. Risk Assessment - Assesses the risks facing the entity as it seeks to achieve its objectives. This assessment provides the basis for developing appropriate risk responses. Information and Communication - The quality information management and personnel communicate and use to support the internal control system. Monitoring - Activities management establishes and operates to assess the quality of performance over time and promptly resolve the findings of audits and other reviews. Furthermore, 2 CFR § 200.303 Internal Controls (a) reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds FEDERAL AWARD NUMBER: SLFRP4587 FEDERAL AWARD YEAR: 2022 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Costs Principles; Procurement and Suspension and Debarment; Reporting; and Subrecipient Monitoring QUESTIONED COSTS: -$0- Condition: During the process of documenting the County’s internal controls regarding federal disbursements, we noted that Washington County has deficiencies in procedures to ensure compliance with the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Costs Principles; Procurement and Suspension and Debarment; Reporting; and Subrecipient Monitoring. • Expenditures are not reviewed for Activities Allowed or Unallowed and Allowable Costs/Costs Principles. • The Interim and Project and Expenditure reports are not approved by the BOCC prior to submission. • Additionally, the contract with a subrecipient was not renewed annually, nor was the full contract amount encumbered at the time the contract was initiated. • The County has not established Subrecipient Monitoring Procedures. o The County did not enforce the reporting requirements as set out in the Subrecipient Agreement. The subrecipient submitted quarterly reports for Quarter 1 and Quarter 2 to the BOCC on August 8, 2022. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal program expenditures are made in accordance with federal compliance requirements. Effect of Condition: This condition attributed to the noncompliance with grant requirements and could lead to the loss of federal funds to the County. Recommendation: OSAI recommends the County gain an understanding of requirements for this program and implement internal control procedures to ensure compliance with all requirements. Management Response: District 1 County Commissioner: Not by way of excuse, but truly in response, the Federal programs associated with the COVID response were unnecessarily arduous and created confusion at all levels of government. While the monetary response was accepted, the premise of these programs was nothing more than an administrative shell game. From the outset of the response, guidance was termed as “interim”, then “final Interim” and finally, “final” (redundancy intentional). The intent of our national level leadership became more apparent as these programs progressed with each iteration of programming being reliant on returned funds from the previous. Without grandstanding, I will simply say that no entity, regardless of their planning with these programs, will be found as fully compliant. As these programs have a sunset in the near term, I suspect these findings will disappear. District 2 County Commissioner: I was not in office the year audited, but I will work with the other elected officials to Implement a system of internal controls to ensure compliance with grant requirements. District 3 County Commissioner: The elected officials will establish sub-recipient monitoring procedures to remain compliant with all requirements for this type of program. Criteria: 2 CFR § 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The GAO Standards – Section 1 – Fundamental Concepts of Internal Control – OV1.01 states in part: Definition of Internal Control Internal control is a process effected by an entity’s oversight body, management, and other personnel that provides reasonable assurance that the objectives of an entity will be achieved. Additionally, GAO Standards – Section 2 – Establishing an Effective Internal Control System – OV2.04 states in part: Components, Principles, and Attributes Control Activities – The actions management establishes through policies and procedures to achieve objectives and respond to risks in the internal control system, which includes the entity’s information system.
2022-007 Maintenance of Documentation of Internal Control Over Compliance U.S. Department of Justice, Passed through Illinois Criminal Justice Information Authority Crime Victim Assistance – Assistance Listing Number 16.575, Pass-through Entity Identifying Number 546-00-1745 Criteria: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that documentation to evidence the operation of internal controls, such as supervisory reviews. Condition: The Corporation did not have sufficient documentation that internal controls were in place and operating effectively for control activities required for assessment of activities allowed or unallowed and for allowable costs/cost principles. The Corporation also did not have sufficient documentation that internal controls were in place and operating effectively for monitoring procedures required for cash management and reporting compliance requirements. Although the Corporation provided documentation supporting the costs reported, there was no formal documentation of the control activities for approval of activities allowed or unallowed and allowable costs/cost principles. Formal documentation of the supervisory review of cash management and supervisory review and approval of the information compiled for the reporting compliance requirement was also unavailable. Cause: The Corporation did not maintain documentation evidencing the operation of specific internal controls. Effect: Lack of properly documented evidence of approval of activities allowed or unallowed and allowable costs/cost principles. Lack of properly documented evidence of supervisory review of cash management and reporting policies and procedures could result in the loss of future funding. Questioned costs: None Identification as a repeat finding, if applicable: 2021-010 Recommendation: We recommend that management reviews current processes, polices, and procedures to ensure that approval of activities allowed or unallowed and approval of allowable costs/cost principles are properly documented. We recommend that management reviews current processes, policies, and procedures to ensure that supervisory review of cash management and reporting compliance requirements are properly documented. View of responsible officials of the auditee: Management agrees with the finding and recommendation.
Federal Program Title(s): ALN 14.267 – Continuum of Care Program ALN 16.575 - Crime Victim Assistance Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Department of Justice (ALN 16.575) Pass-Through Agencies: New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) 2021-VA-979 (10/1/2020-9/30/2021) (16.575) 2022-VA-180 (10/1/2021-9/30/2022) (16.575) Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing, we noted that VSS internal controls were not sufficient or were not operating as designed in order to document approval of allowable costs principals. Questioned costs: $51.60 (14.267) Context: 14.267 - during our testwork over allowable costs principals we noted 12 of the 60 tested transactions did not have sufficient documentation of approval of allowability. Noted 1 of the 60 tested transactions did not have sufficient documentation to substantiate allowable activity under the grant. 16.575 - during our testwork over allowable costs principals we noted 21 of the 60 tested transactions did not have sufficient documentation of approval of allowability. Cause: Lack of established controls and procedures over allowable costs principals. Effect: Possible noncompliance with federal cost principals or grant requirements. Repeat Finding: 2021-004 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals. Views of responsible officials: VSS agrees with CLA and has updated our financial policies to include electronic approval of expenditures through Bill.com. Timesheets and supplements will be reviewed and approved by staff supervisors biweekly to ensure proper allocation of hours worked. Credit Card Expense reports will require Description of item purchased, as well as the funder and class allocation.
Federal Program Title(s): ALN 14.267 – Continuum of Care Program ALN 16.575 - Crime Victim Assistance Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Department of Justice (ALN 16.575) Pass-Through Agencies: New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) 2021-VA-979 (10/1/2020-9/30/2021) (16.575) 2022-VA-180 (10/1/2021-9/30/2022) (16.575) Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing, we noted that VSS internal controls were not sufficient or were not operating as designed in order to document approval of allowable costs principals. Questioned costs: $51.60 (14.267) Context: 14.267 - during our testwork over allowable costs principals we noted 12 of the 60 tested transactions did not have sufficient documentation of approval of allowability. Noted 1 of the 60 tested transactions did not have sufficient documentation to substantiate allowable activity under the grant. 16.575 - during our testwork over allowable costs principals we noted 21 of the 60 tested transactions did not have sufficient documentation of approval of allowability. Cause: Lack of established controls and procedures over allowable costs principals. Effect: Possible noncompliance with federal cost principals or grant requirements. Repeat Finding: 2021-004 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals. Views of responsible officials: VSS agrees with CLA and has updated our financial policies to include electronic approval of expenditures through Bill.com. Timesheets and supplements will be reviewed and approved by staff supervisors biweekly to ensure proper allocation of hours worked. Credit Card Expense reports will require Description of item purchased, as well as the funder and class allocation.
Federal Program Title(s): ALN 14.267 – Continuum of Care Program ALN 16.575 - Crime Victim Assistance Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Department of Justice (ALN 16.575) Pass-Through Agencies: New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) 2021-VA-979 (10/1/2020-9/30/2021) (16.575) 2022-VA-180 (10/1/2021-9/30/2022) (16.575) Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing, we noted that VSS internal controls were not sufficient or were not operating as designed in order to document approval of allowable costs principals. Questioned costs: $51.60 (14.267) Context: 14.267 - during our testwork over allowable costs principals we noted 12 of the 60 tested transactions did not have sufficient documentation of approval of allowability. Noted 1 of the 60 tested transactions did not have sufficient documentation to substantiate allowable activity under the grant. 16.575 - during our testwork over allowable costs principals we noted 21 of the 60 tested transactions did not have sufficient documentation of approval of allowability. Cause: Lack of established controls and procedures over allowable costs principals. Effect: Possible noncompliance with federal cost principals or grant requirements. Repeat Finding: 2021-004 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals. Views of responsible officials: VSS agrees with CLA and has updated our financial policies to include electronic approval of expenditures through Bill.com. Timesheets and supplements will be reviewed and approved by staff supervisors biweekly to ensure proper allocation of hours worked. Credit Card Expense reports will require Description of item purchased, as well as the funder and class allocation.
Federal Program Title(s): ALN 14.267 – Continuum of Care Program ALN 16.575 - Crime Victim Assistance Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Department of Justice (ALN 16.575) Pass-Through Agencies: New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) 2021-VA-979 (10/1/2020-9/30/2021) (16.575) 2022-VA-180 (10/1/2021-9/30/2022) (16.575) Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing, we noted that VSS internal controls were not sufficient or were not operating as designed in order to document approval of allowable costs principals. Questioned costs: $51.60 (14.267) Context: 14.267 - during our testwork over allowable costs principals we noted 12 of the 60 tested transactions did not have sufficient documentation of approval of allowability. Noted 1 of the 60 tested transactions did not have sufficient documentation to substantiate allowable activity under the grant. 16.575 - during our testwork over allowable costs principals we noted 21 of the 60 tested transactions did not have sufficient documentation of approval of allowability. Cause: Lack of established controls and procedures over allowable costs principals. Effect: Possible noncompliance with federal cost principals or grant requirements. Repeat Finding: 2021-004 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals. Views of responsible officials: VSS agrees with CLA and has updated our financial policies to include electronic approval of expenditures through Bill.com. Timesheets and supplements will be reviewed and approved by staff supervisors biweekly to ensure proper allocation of hours worked. Credit Card Expense reports will require Description of item purchased, as well as the funder and class allocation.
Federal Program Title(s): ALN 14.267 – Continuum of Care Program ALN 16.575 - Crime Victim Assistance Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Department of Justice (ALN 16.575) Pass-Through Agencies: New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) 2021-VA-979 (10/1/2020-9/30/2021) (16.575) 2022-VA-180 (10/1/2021-9/30/2022) (16.575) Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing, we noted that VSS internal controls were not sufficient or were not operating as designed in order to document approval of allowable costs principals. Questioned costs: $51.60 (14.267) Context: 14.267 - during our testwork over allowable costs principals we noted 12 of the 60 tested transactions did not have sufficient documentation of approval of allowability. Noted 1 of the 60 tested transactions did not have sufficient documentation to substantiate allowable activity under the grant. 16.575 - during our testwork over allowable costs principals we noted 21 of the 60 tested transactions did not have sufficient documentation of approval of allowability. Cause: Lack of established controls and procedures over allowable costs principals. Effect: Possible noncompliance with federal cost principals or grant requirements. Repeat Finding: 2021-004 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals. Views of responsible officials: VSS agrees with CLA and has updated our financial policies to include electronic approval of expenditures through Bill.com. Timesheets and supplements will be reviewed and approved by staff supervisors biweekly to ensure proper allocation of hours worked. Credit Card Expense reports will require Description of item purchased, as well as the funder and class allocation.
Federal Program Title(s): ALN 14.267 – Continuum of Care Program Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Pass-Through Agencies: N/A Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal 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. Per 24 CFR 578.49(b)(1) - When grants are used to pay rent for all or part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent paid may not exceed rents currently being charged by the same owner for comparable unassisted space. Per 24 CFR 578.49(b)(1) - When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents. Condition: During our testing, we noted that VSS internal controls surrounding fair market rent did not comply with the program requirements. Context and Questioned Costs: During our testing over the special provision for fair market rent, we noted that VSS did not have an updated fair market calculation for 1 of the 5 tested participants. Additionally, noted that the number in the household decreased and there was not an assessment of the fair market rent allowable for the household size. Cause: Lack of established controls and procedures over the program’s fair market rent requirements. Effect: Possible noncompliance with federal requirements and HUD program requirements. Repeat Finding: N/A – New Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal and grantor requirements regarding the program requirements. Views of responsible officials: VSS agrees with CLA and has updated our financial policies. We have hired an accountant, in addition to our Finance Director and Finance Coordinator to create a system of posting and review. Fair Market Rents will be reviewed along with the HQS worksheet and Income Limits during annual recertification for active participants in the HUD program.
Federal Program Title(s): ALN 14.267 – Continuum of Care Program Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Pass-Through Agencies: N/A Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal 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. Per 24 CFR 578.49(b)(1) - When grants are used to pay rent for all or part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent paid may not exceed rents currently being charged by the same owner for comparable unassisted space. Per 24 CFR 578.49(b)(1) - When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents. Condition: During our testing, we noted that VSS internal controls surrounding fair market rent did not comply with the program requirements. Context and Questioned Costs: During our testing over the special provision for fair market rent, we noted that VSS did not have an updated fair market calculation for 1 of the 5 tested participants. Additionally, noted that the number in the household decreased and there was not an assessment of the fair market rent allowable for the household size. Cause: Lack of established controls and procedures over the program’s fair market rent requirements. Effect: Possible noncompliance with federal requirements and HUD program requirements. Repeat Finding: N/A – New Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal and grantor requirements regarding the program requirements. Views of responsible officials: VSS agrees with CLA and has updated our financial policies. We have hired an accountant, in addition to our Finance Director and Finance Coordinator to create a system of posting and review. Fair Market Rents will be reviewed along with the HQS worksheet and Income Limits during annual recertification for active participants in the HUD program.
Federal Program Title(s): ALN 14.267 – Continuum of Care Program Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Pass-Through Agencies: N/A Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal 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. Per 24 CFR 578.49(b)(1) - When grants are used to pay rent for all or part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent paid may not exceed rents currently being charged by the same owner for comparable unassisted space. Per 24 CFR 578.49(b)(1) - When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents. Condition: During our testing, we noted that VSS internal controls surrounding fair market rent did not comply with the program requirements. Context and Questioned Costs: During our testing over the special provision for fair market rent, we noted that VSS did not have an updated fair market calculation for 1 of the 5 tested participants. Additionally, noted that the number in the household decreased and there was not an assessment of the fair market rent allowable for the household size. Cause: Lack of established controls and procedures over the program’s fair market rent requirements. Effect: Possible noncompliance with federal requirements and HUD program requirements. Repeat Finding: N/A – New Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal and grantor requirements regarding the program requirements. Views of responsible officials: VSS agrees with CLA and has updated our financial policies. We have hired an accountant, in addition to our Finance Director and Finance Coordinator to create a system of posting and review. Fair Market Rents will be reviewed along with the HQS worksheet and Income Limits during annual recertification for active participants in the HUD program.
Federal Agency: U.S. Department of Agriculture; U.S. Department of the Treasury Federal Program Name: Child Nutrition Cluster; Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 10.559; 21.027 Federal Award Identification Number and Year: 214RI306N1099/214RI306N1199 - 2022 Award Period: Fiscal Year 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement The Town and Coventry Public Schools must comply with procurement standards set out at 2 CFR sections 200.303 and 200.318 through 200.326 within Uniform Guidance. 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). UG §200.318 General procurement standards. (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. §200.320 states that the non-Federal entity must use one of the prescribed methods of procurement. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in §200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: (1) Micro-purchases. Procurement by micro-purchase is the acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (See the definition of micro-purchase in §200.1). To the maximum extent practicable, the non-Federal entity should distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive price or rate quotations if the non-Federal entity considers the price to be reasonable based on research, experience, purchase history or other information and documents it files accordingly. Purchase cards can be used for micro-purchases if procedures are documented and approved by the non-Federal entity. (2) Small purchase. Procurement by small purchase is the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a noncompetitive procurement can be used in accordance with §200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. Bids are publicly solicited, and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. (2) Proposals. Either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. (c) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the allowed circumstances apply. Condition The Towns purchasing policies within Coventry Public Schools do not include all elements as outlined in 2 CRF sections 200.303 and 200.318 through 200.326 noted above. Questioned Costs None Context Although the Towns purchasing policies within Coventry Public Schools do not include all elements as outlined in 2 CRF sections 200.303 and 200.318 through 200.326, we did not identify transactions where contracts were awarded without proper justification in 4 of 4 procurement transactions tested. Cause Management was not aware of the procurement standards set out at 2 CFR sections 200.303 and 200.318 through 200.326 within Uniform Guidance. Effect The Town and Coventry Public Schools are at risk for noncompliance with Federal grants as it relates to procurement. Repeat Finding Yes Recommendation We recommend that the Town and Coventry Public Schools updates its procurement policy to include all elements identified in 2 CRF sections 200.303 and 200.318 through 200.326. Views of Responsible Officials Management agrees with this finding.
Federal Agency: U.S. Department of Agriculture; U.S. Department of the Treasury Federal Program Name: Child Nutrition Cluster; Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 10.559; 21.027 Federal Award Identification Number and Year: 214RI306N1099/214RI306N1199 - 2022 Award Period: Fiscal Year 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement The Town and Coventry Public Schools must comply with procurement standards set out at 2 CFR sections 200.303 and 200.318 through 200.326 within Uniform Guidance. 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). UG §200.318 General procurement standards. (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. §200.320 states that the non-Federal entity must use one of the prescribed methods of procurement. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in §200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: (1) Micro-purchases. Procurement by micro-purchase is the acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (See the definition of micro-purchase in §200.1). To the maximum extent practicable, the non-Federal entity should distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive price or rate quotations if the non-Federal entity considers the price to be reasonable based on research, experience, purchase history or other information and documents it files accordingly. Purchase cards can be used for micro-purchases if procedures are documented and approved by the non-Federal entity. (2) Small purchase. Procurement by small purchase is the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a noncompetitive procurement can be used in accordance with §200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. Bids are publicly solicited, and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. (2) Proposals. Either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. (c) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the allowed circumstances apply. Condition The Towns purchasing policies within Coventry Public Schools do not include all elements as outlined in 2 CRF sections 200.303 and 200.318 through 200.326 noted above. Questioned Costs None Context Although the Towns purchasing policies within Coventry Public Schools do not include all elements as outlined in 2 CRF sections 200.303 and 200.318 through 200.326, we did not identify transactions where contracts were awarded without proper justification in 4 of 4 procurement transactions tested. Cause Management was not aware of the procurement standards set out at 2 CFR sections 200.303 and 200.318 through 200.326 within Uniform Guidance. Effect The Town and Coventry Public Schools are at risk for noncompliance with Federal grants as it relates to procurement. Repeat Finding Yes Recommendation We recommend that the Town and Coventry Public Schools updates its procurement policy to include all elements identified in 2 CRF sections 200.303 and 200.318 through 200.326. Views of Responsible Officials Management agrees with this finding.
Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: 2022 Award Period: Fiscal Year 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria 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 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). Compliance: 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Condition The Town does not have policies and procedures in place to ensure that they do not contract with or make subawards to parties that are suspended or debarred. Questioned Costs None Context Although the Town does not have policies or procedures in place to ensure that they do not contract with or make subawards to parties that are suspended or debarred, we did not identify instances where Federal grant awards were paid to suspended or debarred vendors for 3 of 3 suspension and debarment transactions selected for testing. Cause Management was not aware of the requirements of 2 CFR section 180 within Uniform Guidance. Effect The Town is at risk for noncompliance with federal grants as it relates to suspension and debarment. Repeat Finding No Recommendation We recommend that the Town implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them ford goods or services. Views of Responsible Officials Management agrees with this finding.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow 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). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow 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). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow 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). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow 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). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow 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). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow 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). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Financial Reporting Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. 2 CFR section 200.302(b))3) requires that nonfederal entities keep records that include info: pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation Condition – The Organization did not maintain proper documentation in support of financial reporting requirements. Cause – Supporting records used to populate the required financial reporting were not retained by the Agency. Effect – The agency could submit incorrect information. Questioned Costs – Not applicable. Recommendation – Documentation should be prepared, reviewed, and retained to support the required reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Financial Reporting Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. 2 CFR section 200.302(b))3) requires that nonfederal entities keep records that include info: pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation Condition – The Organization did not maintain proper documentation in support of financial reporting requirements. Cause – Supporting records used to populate the required financial reporting were not retained by the Agency. Effect – The agency could submit incorrect information. Questioned Costs – Not applicable. Recommendation – Documentation should be prepared, reviewed, and retained to support the required reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Financial Reporting Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. 2 CFR section 200.302(b))3) requires that nonfederal entities keep records that include info: pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation Condition – The Organization did not maintain proper documentation in support of financial reporting requirements. Cause – Supporting records used to populate the required financial reporting were not retained by the Agency. Effect – The agency could submit incorrect information. Questioned Costs – Not applicable. Recommendation – Documentation should be prepared, reviewed, and retained to support the required reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Financial Reporting Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. 2 CFR section 200.302(b))3) requires that nonfederal entities keep records that include info: pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation Condition – The Organization did not maintain proper documentation in support of financial reporting requirements. Cause – Supporting records used to populate the required financial reporting were not retained by the Agency. Effect – The agency could submit incorrect information. Questioned Costs – Not applicable. Recommendation – Documentation should be prepared, reviewed, and retained to support the required reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Financial Reporting Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. 2 CFR section 200.302(b))3) requires that nonfederal entities keep records that include info: pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation Condition – The Organization did not maintain proper documentation in support of financial reporting requirements. Cause – Supporting records used to populate the required financial reporting were not retained by the Agency. Effect – The agency could submit incorrect information. Questioned Costs – Not applicable. Recommendation – Documentation should be prepared, reviewed, and retained to support the required reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Financial Reporting Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. 2 CFR section 200.302(b))3) requires that nonfederal entities keep records that include info: pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation Condition – The Organization did not maintain proper documentation in support of financial reporting requirements. Cause – Supporting records used to populate the required financial reporting were not retained by the Agency. Effect – The agency could submit incorrect information. Questioned Costs – Not applicable. Recommendation – Documentation should be prepared, reviewed, and retained to support the required reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Special Reporting Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, under compliance requirements for reporting 2 CFR 200.32 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. 2 CFR 200.330, Reporting on Real Property: The Federal awarding agency or pass-through entity must require a non-Federal entity to submit reports at least annually on the status of real property in which the Federal Government retains an interest. As described in ACF-IM-HS-17-01 Facilities Guidance, all grantees, including those with no covered real property, are instructed to use and submit standard form (SF) Real Property Status Report 429. Condition – The SF-429 required to be filed for Head Start was submitted after the deadline. Cause – The Agency did not apply appropriate controls to ensure that all reporting required under the terms of the grant were filed timely. Effect – Late reporting to the grantor can result in sanctions or loss of future funding. Questioned Costs – Not applicable. Recommendation – Management should implement the necessary controls to ensure all reporting required under the grant is filed accurately and timely. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Special Reporting Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, under compliance requirements for reporting 2 CFR 200.32 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. 2 CFR 200.330, Reporting on Real Property: The Federal awarding agency or pass-through entity must require a non-Federal entity to submit reports at least annually on the status of real property in which the Federal Government retains an interest. As described in ACF-IM-HS-17-01 Facilities Guidance, all grantees, including those with no covered real property, are instructed to use and submit standard form (SF) Real Property Status Report 429. Condition – The SF-429 required to be filed for Head Start was submitted after the deadline. Cause – The Agency did not apply appropriate controls to ensure that all reporting required under the terms of the grant were filed timely. Effect – Late reporting to the grantor can result in sanctions or loss of future funding. Questioned Costs – Not applicable. Recommendation – Management should implement the necessary controls to ensure all reporting required under the grant is filed accurately and timely. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Special Reporting Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, under compliance requirements for reporting 2 CFR 200.32 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. 2 CFR 200.330, Reporting on Real Property: The Federal awarding agency or pass-through entity must require a non-Federal entity to submit reports at least annually on the status of real property in which the Federal Government retains an interest. As described in ACF-IM-HS-17-01 Facilities Guidance, all grantees, including those with no covered real property, are instructed to use and submit standard form (SF) Real Property Status Report 429. Condition – The SF-429 required to be filed for Head Start was submitted after the deadline. Cause – The Agency did not apply appropriate controls to ensure that all reporting required under the terms of the grant were filed timely. Effect – Late reporting to the grantor can result in sanctions or loss of future funding. Questioned Costs – Not applicable. Recommendation – Management should implement the necessary controls to ensure all reporting required under the grant is filed accurately and timely. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Special Reporting Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, under compliance requirements for reporting 2 CFR 200.32 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. 2 CFR 200.330, Reporting on Real Property: The Federal awarding agency or pass-through entity must require a non-Federal entity to submit reports at least annually on the status of real property in which the Federal Government retains an interest. As described in ACF-IM-HS-17-01 Facilities Guidance, all grantees, including those with no covered real property, are instructed to use and submit standard form (SF) Real Property Status Report 429. Condition – The SF-429 required to be filed for Head Start was submitted after the deadline. Cause – The Agency did not apply appropriate controls to ensure that all reporting required under the terms of the grant were filed timely. Effect – Late reporting to the grantor can result in sanctions or loss of future funding. Questioned Costs – Not applicable. Recommendation – Management should implement the necessary controls to ensure all reporting required under the grant is filed accurately and timely. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Special Reporting Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, under compliance requirements for reporting 2 CFR 200.32 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. 2 CFR 200.330, Reporting on Real Property: The Federal awarding agency or pass-through entity must require a non-Federal entity to submit reports at least annually on the status of real property in which the Federal Government retains an interest. As described in ACF-IM-HS-17-01 Facilities Guidance, all grantees, including those with no covered real property, are instructed to use and submit standard form (SF) Real Property Status Report 429. Condition – The SF-429 required to be filed for Head Start was submitted after the deadline. Cause – The Agency did not apply appropriate controls to ensure that all reporting required under the terms of the grant were filed timely. Effect – Late reporting to the grantor can result in sanctions or loss of future funding. Questioned Costs – Not applicable. Recommendation – Management should implement the necessary controls to ensure all reporting required under the grant is filed accurately and timely. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Special Reporting Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, under compliance requirements for reporting 2 CFR 200.32 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. 2 CFR 200.330, Reporting on Real Property: The Federal awarding agency or pass-through entity must require a non-Federal entity to submit reports at least annually on the status of real property in which the Federal Government retains an interest. As described in ACF-IM-HS-17-01 Facilities Guidance, all grantees, including those with no covered real property, are instructed to use and submit standard form (SF) Real Property Status Report 429. Condition – The SF-429 required to be filed for Head Start was submitted after the deadline. Cause – The Agency did not apply appropriate controls to ensure that all reporting required under the terms of the grant were filed timely. Effect – Late reporting to the grantor can result in sanctions or loss of future funding. Questioned Costs – Not applicable. Recommendation – Management should implement the necessary controls to ensure all reporting required under the grant is filed accurately and timely. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed/Allowable Costs/Costs Principles, Eligibility, Period of Performance Emergency Rental Assistance ALN# 21.023 US Department of the Treasury Passed through Oregon Housing and Community Services Federal Grant/Contract Number: ERA000 Grant period – 2022 Criteria – 2 CFR 200.303 requires non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, activities allowed, beneficiary eligibility, and period of performance. For the Emergency Rental Assistance Program, specific requirements are laid out in Section 501 of Division N of the Consolidated Appropriations Act, 2021, 2 CFR Part 200, Subpart E, federal awarding agency regulations, and the terms and conditions of the award. Condition – In our sample of 100 items, we noted the following exceptions: • 2 instances where client applications nor check requests could be produced • 2 instances where client applications could not be produced • 1 instance where the risk of housing status was not properly documented. Cause – Supporting applications and/or required documentation was not retained by the Agency to substantiate eligibility, allowable costs, activities allowed, and period of performance for benefit services rendered. Effect – Failure to properly document eligibility determinations and benefit amounts could result in improper payments and disallowed costs. Questioned Costs – $ 137,567. Recommendation – Documentation should be prepared, reviewed, and retained to support the allowable costs, activities allowed, eligibility, and period of performance for benefits paid to individuals for services. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed/Allowable Costs/Costs Principles, Period of Performance Emergency Rental Assistance ALN# 21.023 US Department of the Treasury Passed through Oregon Housing and Community Services Federal Grant/Contract Number: ERA000 Grant period – 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition – In our sample of 100 items, we noted the following exceptions: • 13 instances where the check request used to identify approval of the disbursement could not be located • 1 instance where the request was not signed by the supervisor Cause – Supporting check request documentation relevant to verify that proper approval controls had been performed could not be obtained. Effect – Expenses not relevant to the fund or client benefits could be paid without approval. Expenses could be in excess of costs that client was eligible for or could be outside of the period of performance. Questioned Costs – Not applicable. Recommendation – Documentation should be prepared, reviewed, and retained to support the allowable costs, activities allowed, eligibility, and period of performance for benefits paid to individuals for services. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Federal Program: COVID-19: Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Assistance Listing Number: 93.498 Federal Agency: U.S. Department of Health and Human Services Award Number: N/A Award Year: 2022 Compliance Requirement: N/A Questioned Costs: Not applicable Criteria: Nonfederal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes properly identifying all federal awards subject to Uniform Guidance. Condition/Context: Inglis failed to identify all federal awards subject to the Uniform Guidance. The preliminary schedule of expenditures of federal awards only included ALN 93.498, COVID-19: Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution. The Schedule was missing ALN 97.036 and 14.912. In addition, there was no documented evidence of formal review of the Schedule. Effect: Federal grants subject to the Uniform Guidance may not be captured, audited and reported on in accordance with the requirements of the associated grant agreement. Cause: Inglis did not have a formal process to track, review and report on all federal awards subject to the Uniform Guidance. Recommendation: Inglis should implement a formal process to identify and accumulate all federal award information to evaluate the appropriate requirements, including those subject to the Uniform Guidance. Managements Response: The omission of occurred as a result of timing of receipt of award and not knowing all unsolicited funding had to be reported on SEFA schedule. The error has been corrected. Management did perform a review however there was no documentation maintained of this process. There are specific ledger codes used to track all grants. The SEFA will be prepared by the Controller and signed off on by the CFO.
Federal Program: COVID-19: Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Assistance Listing Number: 93.498 Federal Agency: U.S. Department of Health and Human Services Award Number: N/A Award Year: 2022 Compliance Requirement: N/A Questioned Costs: Not applicable Criteria: Nonfederal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes properly identifying all federal awards subject to Uniform Guidance. Condition/Context: Inglis failed to identify all federal awards subject to the Uniform Guidance. The preliminary schedule of expenditures of federal awards only included ALN 93.498, COVID-19: Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution. The Schedule was missing ALN 97.036 and 14.912. In addition, there was no documented evidence of formal review of the Schedule. Effect: Federal grants subject to the Uniform Guidance may not be captured, audited and reported on in accordance with the requirements of the associated grant agreement. Cause: Inglis did not have a formal process to track, review and report on all federal awards subject to the Uniform Guidance. Recommendation: Inglis should implement a formal process to identify and accumulate all federal award information to evaluate the appropriate requirements, including those subject to the Uniform Guidance. Managements Response: The omission of occurred as a result of timing of receipt of award and not knowing all unsolicited funding had to be reported on SEFA schedule. The error has been corrected. Management did perform a review however there was no documentation maintained of this process. There are specific ledger codes used to track all grants. The SEFA will be prepared by the Controller and signed off on by the CFO.
Program Name: Community Facilities Loans and Grants Cluster Federal Assistance Listing Number: 10.766 Federal Agency: U.S. Department of Agriculture Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions Questioned Costs: None Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The District did not establish a debt reserve fund as required by the federal award agreement. Cause: The District lacked a system of internal controls necessary to ensure the reserve fund balance was in compliance with the federal award agreement. Effect: The lack of adequate policies governing the monitoring of the required debt covenants and the establishment and funding reserves increases the risk that employees may not be able to detect and correct noncompliance in a timely manner. Recommendation: We recommend that management establish the required reserve fund. View of Responsible Officials: Management agrees with this finding and has committed the resources necessary to maintaining an adequate reserve fund.
ALN 84.425 Elementary and Secondary School Emergency Fund Program United States Department of Education Passed through State of Louisiana Department of Education 2022 Funding Criteria: In accordance with 2 CFR Part 200.303(a), the School must establish, document, and maintain effective internal control over Federal awards that provide reasonable assurance that the recipient of subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, 2 CFR 200.508(d) requires that the auditee ‘provide the auditor access to personnel, accounts, books, records, supporting documentation, and any other information needed for the auditor to perform the audit required by this part.’ Condition: The School did not maintain documentation for amounts submitted for reimbursement through the program. As a result, we were unable to obtain sufficient, appropriate audit evidence to support $111,006, or approximately 25%, of the total expenditures reimbursed under the Education Stabilization Fund during the year ended June 30, 2022. Thus, we were unable to form a conclusion on the School’s compliance with direct and material requirements for a material portion of Federal award expenditures. Cause: The change in key finance department personnel caused misplacement of some of the documentation supporting the program expenditures. Effect: Amounts could be reimbursed that are not properly supported and the federal agency could request repayment of the unsupported reimbursement amounts. Questioned Costs: None Recommendation: We recommend that the School revise and implement controls to ensure consistent maintenance of all supporting documentation even if there are changes in personnel. Management Response: See corrective action plan on page 33.
ALN 84.425 Elementary and Secondary School Emergency Fund Program United States Department of Education Passed through State of Louisiana Department of Education 2022 Funding Criteria: In accordance with 2 CFR Part 200.303(a), the School must establish, document, and maintain effective internal control over Federal awards that provide reasonable assurance that the recipient of subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, 2 CFR 200.508(d) requires that the auditee ‘provide the auditor access to personnel, accounts, books, records, supporting documentation, and any other information needed for the auditor to perform the audit required by this part.’ Condition: The School did not maintain documentation for amounts submitted for reimbursement through the program. As a result, we were unable to obtain sufficient, appropriate audit evidence to support $111,006, or approximately 25%, of the total expenditures reimbursed under the Education Stabilization Fund during the year ended June 30, 2022. Thus, we were unable to form a conclusion on the School’s compliance with direct and material requirements for a material portion of Federal award expenditures. Cause: The change in key finance department personnel caused misplacement of some of the documentation supporting the program expenditures. Effect: Amounts could be reimbursed that are not properly supported and the federal agency could request repayment of the unsupported reimbursement amounts. Questioned Costs: None Recommendation: We recommend that the School revise and implement controls to ensure consistent maintenance of all supporting documentation even if there are changes in personnel. Management Response: See corrective action plan on page 33.
ALN 84.425 Elementary and Secondary School Emergency Fund Program United States Department of Education Passed through State of Louisiana Department of Education 2022 Funding Criteria: In accordance with 2 CFR Part 200.303(a), the School must establish, document, and maintain effective internal control over Federal awards that provide reasonable assurance that the recipient of subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, 2 CFR 200.508(d) requires that the auditee ‘provide the auditor access to personnel, accounts, books, records, supporting documentation, and any other information needed for the auditor to perform the audit required by this part.’ Condition: The School did not maintain documentation for amounts submitted for reimbursement through the program. As a result, we were unable to obtain sufficient, appropriate audit evidence to support $111,006, or approximately 25%, of the total expenditures reimbursed under the Education Stabilization Fund during the year ended June 30, 2022. Thus, we were unable to form a conclusion on the School’s compliance with direct and material requirements for a material portion of Federal award expenditures. Cause: The change in key finance department personnel caused misplacement of some of the documentation supporting the program expenditures. Effect: Amounts could be reimbursed that are not properly supported and the federal agency could request repayment of the unsupported reimbursement amounts. Questioned Costs: None Recommendation: We recommend that the School revise and implement controls to ensure consistent maintenance of all supporting documentation even if there are changes in personnel. Management Response: See corrective action plan on page 33.
Condition: During our review and reconciliation of the Schedule of Expenditures of Federal Awards (SEFA) as initially prepared by the County, we identified federal programs that were not listed accurately which resulted in federal expenditures being overstated stated by $2,412,977. • Expenditures reported on the SEFA for ALN 16.607 - Bulletproof Vest Partnership Program were $36,810. Actual federal expenditures obtained from the County’s records confirm $0 expended for a variance of $36,810. • Expenditures reported on the SEFA for ALN 21.019 - Coronavirus Relief Fund were $2,376,264. Actual federal expenditures obtained from the County’s records confirm $0 expended for a variance of $2,376,264. Expenditures reported on the SEFA for ALN 97.042 - Emergency Management Performance Grants were $24,864. Actual federal expenditures obtained from the County’s records confirm $24,961 expended for a variance of ($97). Additionally, the County failed to present $500,000 in subrecipient expenditures on the SEFA for ALN 21.027 - Coronavirus State and Local Fiscal Recovery Funds. Cause of Condition: Policies and procedures have not been designed and implemented to ensure accurate reporting of expenditures for all federal awards. Effect of Condition: This condition resulted in inaccurate recording of the federal expenditures on the SEFA. Recommendation: OSAI recommends county officials and department heads gain an understanding of federal programs awarded to Rogers County. Internal control procedures should be designed and implemented to ensure accurate reporting of expenditures on the SEFA and to ensure compliance with federal requirements. The Board of County Commissioners (BOCC) should review and approve the SEFA in an open meeting. Management Response: Board of County Commissioners: The Board of County Commissioners is responsible for the overall fiscal concerns of the county. See OKLA. STAT. Title 19, § 345. The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. Additionally, the Board of County Commissioners conducts meetings with all elected officials and officers responsible for the receipt and/or expenditure of county funds. These meetings address fiscal matters, including but not limited to, policy discussions and implementation, financial reports, budget oversight, SEFA reporting, and legal compliance. Policies and procedures, combined with fiscal oversight meetings, are intended to: 1) prevent or detect material misstatements in the financial statements; 2) prevent or detect fraud within the county; 3) increase communication between the Board of County Commissioners and those elected officials and officers responsible for the receipt and/or expenditure of public funds; 4) provide oversight over the fiscal concerns of the county; 5) identify and address risks related to financial reporting; 6) ensure the accuracy of Rogers County’s financial statements, Estimate of Needs, and the SEFA; and 7) ensure compliance with all applicable federal and state laws, regulations, and/or codes. The Board of County Commissioners, with the cooperation of all elected officials and officers responsible for the receipt or expenditure of federal funds, will evaluate the processes and procedures currently in place to ensure the accuracy of SEFA reporting and detect potential inaccuracies and/or misstatements. Criteria: 2 CFR § 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR § 200.508(b) Auditee responsibilities reads as follows: The auditee must: Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. 2 CFR § 200.510(b) Financial statements reads, in part, as follows: Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. Further, GAO Standards – Section 2 – Objectives of an Entity - OV2.23 states in part: Compliance Objectives Management conducts activities in accordance with applicable laws and regulations. As part of specifying compliance objectives, the entity determines which laws and regulations apply to the entity. Management is expected to set objectives that incorporate these requirements.
Condition: During the process of documenting the County’s internal controls regarding federal disbursements, we noted that Rogers County has not established procedures to ensure compliance with the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Procurement and Suspension and Debarment; Reporting; and Subrecipient Monitoring. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with federal compliance requirements. Effect of Condition: This condition could result in noncompliance with grant requirements and could lead to a loss of federal funds to the County. Recommendation: OSAI recommends that the County gain an understanding of requirements for this program and implement a system of internal control procedures to ensure compliance with grant requirements. Management Response: Board of County Commissioners: The Board of County Commissioners is responsible for the overall fiscal concerns of the county. See OKLA. STAT. Title 19, § 345. The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. These policies and procedures will be designed to identify requirements for recipients and sub-recipients of grants, ensure accurate equipment and real property management, procurement, recipient and subrecipient monitoring and reporting. Further, policies will ensure a proper understanding of all grant requirements and compliance of the same. To assist in this process, the Board of County Commissioners engaged a third-party administrator to oversee the grant process, including application, eligibility, review, requirements, contracting, recipient tracking and oversight, and documentation and reporting. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration. Criteria: OMB 2 CFR 200, Subpart D. 200.303(a) reads as follows: Subpart D-Post Federal Award Requirements § 200.303 Internal Controls The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Further, accountability and stewardship should be overall goals in management’s accounting of federal funds. Internal controls should be designed to monitor compliance with laws and regulations pertaining to grant contracts.