Condition: During the test of 100% of expenditures, two (2) expenditures totaling $570,080, for the Coronavirus State and Local Fiscal Recovery Funds, the following noncompliance with the Procurement and Suspension and Debarment compliance requirement was noted: • The County failed to properly document the expenditure for one (1) of the two (2) federal expenditures totaling $500,000. They did not execute a contract or award documents, and the invoice was not itemized. This expenditure had a questioned cost of $500,000. 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 resulted in noncompliance with federal grant requirements and could result in a loss of federal funds. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these 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: 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 § 200.320 Internal Controls reads as follows: There are three types of procurement methods described in this section: informal procurement methods (for micro-purchases and simplified acquisitions); formal procurement methods (through sealed bids or proposals); and noncompetitive procurement methods. For any of these methods, the recipient or subrecipient must maintain and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319.
Condition: During the test of 100% of expenditures, two (2) expenditures totaling $570,080, for the Coronavirus State and Local Fiscal Recovery Funds, the following noncompliance with the Reporting compliance requirement was noted: • The interim and the 3rd quarter reports were not submitted. • The 2nd quarter report was not timely submitted. • The County improperly reported a vendor as a subrecipient instead of as a vendor relationship. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are properly reported in accordance with federal compliance requirements. Effect of Condition: This condition resulted in noncompliance with federal grant guidelines. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these 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: 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. Title 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 Guidance, State and Local Fiscal Recovery Funds (10. Reporting) reads as follows: All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlines in Part 2 of this guidance. Expenditures may be reported on a cash of accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, your organization needs to establish internal controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Further, 2 CFR 200.329-Monitoring and reporting Program Performance (c)(1) reads as follows: (c)(1) The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar gays after the period of performance end date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance reports as required by the terms and conditions of the Federal award. See also §200.344. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report.
2022-002 Improve Internal Controls and Documentation over Allowable Costs and Eligibility Determinations Federal Program Information Federal Agency: Department of the Treasury Award Name: COVID-19 Emergency Rental Assistance Program Assistance Listing Number: 21.023 Award Year: 2022 Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement Per 2 CFR 200.303, the County is required to establish and maintain effective internal controls over federal programs to provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of the award. Additionally, 2 CFR 200.334 requires the retention of records and supporting documentation to demonstrate eligibility determinations and allowability of expenditures under the program. Condition and Context During our audit, we tested a sample of 40 selections for allowable costs, as well as a sample of 40 for individual eligibility determinations under the program in which 35 selections were leveraged between the two tests. For 8 of the items selected for testing under allowable cost compliance and eligibility requirements, the County was unable to provide some or all of the required supporting documentation to demonstrate that individuals met the program’s eligibility requirements and that costs were allowable. The documentation was retained in an online portal to which the County no longer had access at the time of our audit procedures. Cause The County did not establish sufficient procedures or controls to ensure ongoing access to required supporting documentation maintained in the external portal used for program administration. Effect or Potential Effect Due to the weakness in internal controls noted above, the County could not demonstrate compliance with eligibility and allowable cost requirements for the sampled transactions. This also constitutes noncompliance with record retention requirements and impairs the ability for sufficient procedures to be performed over the program. Questioned Costs Due to the condition noted above, we were unable to determine if the costs charged to the applicable grant are allowable. Recommendation The County should implement policies and procedures to ensure required documentation for the program is retained in a manner that ensures continued access, even if administration platforms change or external portals are no longer accessible. The County should also periodically verify that it retains all necessary support for program transactions as required under federal regulations. Views of Responsible Official and Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Federal Program Information Federal Agency: Department of the Treasury Award Name: COVID-19 Emergency Rental Assistance Program Assistance Listing Number: 21.023 Award Year: 2022 Compliance Requirement: Reporting Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement Per 2 CFR 200.303, the County is required to establish and maintain effective internal controls over federal programs to provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of the award. Program guidance requires timely and accurate submission of quarterly financial and performance reports, as well as monthly performance reports, to the U.S. Department of the Treasury in accordance with established deadlines. Condition and Context During our testing of the reporting compliance requirement for ERA 1 and ERA 2 awards over the quarterly financial reports, quarterly performance reports and monthly performance reports, we noted the following exceptions: • Of the 2 quarterly financial reports (SF-425) tested, both the ERA 1 and ERA 2 reports for quarter end 9/30/2021 were submitted on 12/31/2021 after the required deadline of 10/29/2021. The County indicated the late submissions were due to the inability to retrieve the information required to compile the reports due to an ERAP system error. • Of the 4 monthly performance reports tested, the County was unable to provide documentation showing the date of submission for the ERA 1 and ERA 2 reports for the month of October 2021. The remaining 2 monthly performance reports for the month of April 2022 were submitted in July 2022, and no approved extension was on file. • Of the 2 quarterly performance reports tested, the ERA 1 report for quarter end 9/30/2021 was submitted on 12/31/2021 after the required deadline of 10/29/2021 due to the inability to retrieve the information required to compile the reports due to an ERA system error. The other quarterly performance report tested for ERA 2 for the quarter ending 6/30/2022 was not submitted on time as evidence by a notification email from Treasury after the due date had passed. Cause The County did not establish sufficient procedures or controls to ensure timely submission of all required reports or retention of sufficient evidence to support timeliness of filing. In addition, the County did not have a contingency process in place to address system errors affecting timely reporting. Effect or Potential Effect Due to the weakness in internal controls noted above, there is an increased risk that required program information may not be reported to the granting agency in a timely manner consistent with federal reporting requirements. Additionally, the lack of supporting documentation impedes the ability to verify compliance with reporting deadlines. No questioned costs are reported as the requirement is procedural in nature. Recommendation The County should strengthen internal controls in place over the timely submission and documentation of required reports for the program. This should include maintaining sufficient evidence of the date and method of submission and considering the implementation of backup procedures in the event system issues affect timely reporting. The County should ensure any delays are documented and, if necessary, approved by the granting agency in writing. Views of Responsible Official and Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained. Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality. Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval. Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained. Effect: The salaries charged are subject to disallowance and are considered questioned costs. Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained. Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality. Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval. Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained. Effect: The salaries charged are subject to disallowance and are considered questioned costs. Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained. Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality. Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval. Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained. Effect: The salaries charged are subject to disallowance and are considered questioned costs. Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained. Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality. Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval. Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained. Effect: The salaries charged are subject to disallowance and are considered questioned costs. Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained. Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality. Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval. Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained. Effect: The salaries charged are subject to disallowance and are considered questioned costs. Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained. Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality. Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval. Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained. Effect: The salaries charged are subject to disallowance and are considered questioned costs. Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained. Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality. Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval. Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained. Effect: The salaries charged are subject to disallowance and are considered questioned costs. Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained. Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality. Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval. Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained. Effect: The salaries charged are subject to disallowance and are considered questioned costs. Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained. Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality. Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval. Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained. Effect: The salaries charged are subject to disallowance and are considered questioned costs. Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained. Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality. Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval. Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained. Effect: The salaries charged are subject to disallowance and are considered questioned costs. Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: The District charged costs to the program which were not properly approved. Questioned Costs: None. Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment. Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment. Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs. Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: The District charged costs to the program which were not properly approved. Questioned Costs: None. Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment. Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment. Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs. Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: The District charged costs to the program which were not properly approved. Questioned Costs: None. Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment. Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment. Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs. Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: The District charged costs to the program which were not properly approved. Questioned Costs: None. Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment. Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment. Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs. Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: The District charged costs to the program which were not properly approved. Questioned Costs: None. Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment. Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment. Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs. Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: The District charged costs to the program which were not properly approved. Questioned Costs: None. Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment. Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment. Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs. Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: The District charged costs to the program which were not properly approved. Questioned Costs: None. Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment. Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment. Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs. Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: The District charged costs to the program which were not properly approved. Questioned Costs: None. Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment. Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment. Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs. Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: The District charged costs to the program which were not properly approved. Questioned Costs: None. Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment. Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment. Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs. Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Allowable Costs/Cost Principles Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards. Condition: The District charged costs to the program which were not properly approved. Questioned Costs: None. Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment. Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment. Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs. Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained. Views of responsible officials: There is no disagreement with the audit finding.
2022-003 Allowable Costs – Payroll, Fringe, and General Disbursements Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Allowable costs must be approved by the awarding agency (2 CFR section 200.407) and necessary and reasonable for the performance of the federal award and allocable under the principles of 2 CFR, Subpart E. Additionally, costs must be adequately documented. Condition: Direct costs incurred were allocated through journal entries to the grant without support of an allocation methodology. Management was unable to provide an understanding of how to trace the allocated amounts to a consistent methodology or to original source documentation. Additionally, credit card costs did not have proper evidence of approval maintained. Lastly, time and effort was not supported for one transaction for the amount charged to the grant. Context: Of the general disbursement population, $121,199 of general disbursements were booked via unsupported journal entry (allocated). Of the payroll and fringe benefit disbursement population, $120,483 were booked via unsupported journal entry (allocated). Lastly, one of the forty payroll transactions tested did not agree to the amount charged to the grant. Questioned Costs: $241,682 Cause: Internal controls surrounding allocations were not properly designed and implemented and an audit trail for allocation journal entries/source documentation was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over allocations provides an opportunity for noncompliance and errors. Repeat Finding: Yes Recommendation: We recommend that the Organization design, implement and monitor internal controls over allocations as well as maintain source documentation to support amounts charged to the grant. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
2022-003 Allowable Costs – Payroll, Fringe, and General Disbursements Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Allowable costs must be approved by the awarding agency (2 CFR section 200.407) and necessary and reasonable for the performance of the federal award and allocable under the principles of 2 CFR, Subpart E. Additionally, costs must be adequately documented. Condition: Direct costs incurred were allocated through journal entries to the grant without support of an allocation methodology. Management was unable to provide an understanding of how to trace the allocated amounts to a consistent methodology or to original source documentation. Additionally, credit card costs did not have proper evidence of approval maintained. Lastly, time and effort was not supported for one transaction for the amount charged to the grant. Context: Of the general disbursement population, $121,199 of general disbursements were booked via unsupported journal entry (allocated). Of the payroll and fringe benefit disbursement population, $120,483 were booked via unsupported journal entry (allocated). Lastly, one of the forty payroll transactions tested did not agree to the amount charged to the grant. Questioned Costs: $241,682 Cause: Internal controls surrounding allocations were not properly designed and implemented and an audit trail for allocation journal entries/source documentation was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over allocations provides an opportunity for noncompliance and errors. Repeat Finding: Yes Recommendation: We recommend that the Organization design, implement and monitor internal controls over allocations as well as maintain source documentation to support amounts charged to the grant. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
2022-003 Allowable Costs – Payroll, Fringe, and General Disbursements Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Allowable costs must be approved by the awarding agency (2 CFR section 200.407) and necessary and reasonable for the performance of the federal award and allocable under the principles of 2 CFR, Subpart E. Additionally, costs must be adequately documented. Condition: Direct costs incurred were allocated through journal entries to the grant without support of an allocation methodology. Management was unable to provide an understanding of how to trace the allocated amounts to a consistent methodology or to original source documentation. Additionally, credit card costs did not have proper evidence of approval maintained. Lastly, time and effort was not supported for one transaction for the amount charged to the grant. Context: Of the general disbursement population, $121,199 of general disbursements were booked via unsupported journal entry (allocated). Of the payroll and fringe benefit disbursement population, $120,483 were booked via unsupported journal entry (allocated). Lastly, one of the forty payroll transactions tested did not agree to the amount charged to the grant. Questioned Costs: $241,682 Cause: Internal controls surrounding allocations were not properly designed and implemented and an audit trail for allocation journal entries/source documentation was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over allocations provides an opportunity for noncompliance and errors. Repeat Finding: Yes Recommendation: We recommend that the Organization design, implement and monitor internal controls over allocations as well as maintain source documentation to support amounts charged to the grant. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
2022-003 Allowable Costs – Payroll, Fringe, and General Disbursements Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Allowable costs must be approved by the awarding agency (2 CFR section 200.407) and necessary and reasonable for the performance of the federal award and allocable under the principles of 2 CFR, Subpart E. Additionally, costs must be adequately documented. Condition: Direct costs incurred were allocated through journal entries to the grant without support of an allocation methodology. Management was unable to provide an understanding of how to trace the allocated amounts to a consistent methodology or to original source documentation. Additionally, credit card costs did not have proper evidence of approval maintained. Lastly, time and effort was not supported for one transaction for the amount charged to the grant. Context: Of the general disbursement population, $121,199 of general disbursements were booked via unsupported journal entry (allocated). Of the payroll and fringe benefit disbursement population, $120,483 were booked via unsupported journal entry (allocated). Lastly, one of the forty payroll transactions tested did not agree to the amount charged to the grant. Questioned Costs: $241,682 Cause: Internal controls surrounding allocations were not properly designed and implemented and an audit trail for allocation journal entries/source documentation was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over allocations provides an opportunity for noncompliance and errors. Repeat Finding: Yes Recommendation: We recommend that the Organization design, implement and monitor internal controls over allocations as well as maintain source documentation to support amounts charged to the grant. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
2022-003 Allowable Costs – Payroll, Fringe, and General Disbursements Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Allowable costs must be approved by the awarding agency (2 CFR section 200.407) and necessary and reasonable for the performance of the federal award and allocable under the principles of 2 CFR, Subpart E. Additionally, costs must be adequately documented. Condition: Direct costs incurred were allocated through journal entries to the grant without support of an allocation methodology. Management was unable to provide an understanding of how to trace the allocated amounts to a consistent methodology or to original source documentation. Additionally, credit card costs did not have proper evidence of approval maintained. Lastly, time and effort was not supported for one transaction for the amount charged to the grant. Context: Of the general disbursement population, $121,199 of general disbursements were booked via unsupported journal entry (allocated). Of the payroll and fringe benefit disbursement population, $120,483 were booked via unsupported journal entry (allocated). Lastly, one of the forty payroll transactions tested did not agree to the amount charged to the grant. Questioned Costs: $241,682 Cause: Internal controls surrounding allocations were not properly designed and implemented and an audit trail for allocation journal entries/source documentation was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over allocations provides an opportunity for noncompliance and errors. Repeat Finding: Yes Recommendation: We recommend that the Organization design, implement and monitor internal controls over allocations as well as maintain source documentation to support amounts charged to the grant. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
2022-003 Allowable Costs – Payroll, Fringe, and General Disbursements Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Allowable costs must be approved by the awarding agency (2 CFR section 200.407) and necessary and reasonable for the performance of the federal award and allocable under the principles of 2 CFR, Subpart E. Additionally, costs must be adequately documented. Condition: Direct costs incurred were allocated through journal entries to the grant without support of an allocation methodology. Management was unable to provide an understanding of how to trace the allocated amounts to a consistent methodology or to original source documentation. Additionally, credit card costs did not have proper evidence of approval maintained. Lastly, time and effort was not supported for one transaction for the amount charged to the grant. Context: Of the general disbursement population, $121,199 of general disbursements were booked via unsupported journal entry (allocated). Of the payroll and fringe benefit disbursement population, $120,483 were booked via unsupported journal entry (allocated). Lastly, one of the forty payroll transactions tested did not agree to the amount charged to the grant. Questioned Costs: $241,682 Cause: Internal controls surrounding allocations were not properly designed and implemented and an audit trail for allocation journal entries/source documentation was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over allocations provides an opportunity for noncompliance and errors. Repeat Finding: Yes Recommendation: We recommend that the Organization design, implement and monitor internal controls over allocations as well as maintain source documentation to support amounts charged to the grant. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
2022-003 Allowable Costs – Payroll, Fringe, and General Disbursements Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Allowable costs must be approved by the awarding agency (2 CFR section 200.407) and necessary and reasonable for the performance of the federal award and allocable under the principles of 2 CFR, Subpart E. Additionally, costs must be adequately documented. Condition: Direct costs incurred were allocated through journal entries to the grant without support of an allocation methodology. Management was unable to provide an understanding of how to trace the allocated amounts to a consistent methodology or to original source documentation. Additionally, credit card costs did not have proper evidence of approval maintained. Lastly, time and effort was not supported for one transaction for the amount charged to the grant. Context: Of the general disbursement population, $121,199 of general disbursements were booked via unsupported journal entry (allocated). Of the payroll and fringe benefit disbursement population, $120,483 were booked via unsupported journal entry (allocated). Lastly, one of the forty payroll transactions tested did not agree to the amount charged to the grant. Questioned Costs: $241,682 Cause: Internal controls surrounding allocations were not properly designed and implemented and an audit trail for allocation journal entries/source documentation was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over allocations provides an opportunity for noncompliance and errors. Repeat Finding: Yes Recommendation: We recommend that the Organization design, implement and monitor internal controls over allocations as well as maintain source documentation to support amounts charged to the grant. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
2022-003 Allowable Costs – Payroll, Fringe, and General Disbursements Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Allowable costs must be approved by the awarding agency (2 CFR section 200.407) and necessary and reasonable for the performance of the federal award and allocable under the principles of 2 CFR, Subpart E. Additionally, costs must be adequately documented. Condition: Direct costs incurred were allocated through journal entries to the grant without support of an allocation methodology. Management was unable to provide an understanding of how to trace the allocated amounts to a consistent methodology or to original source documentation. Additionally, credit card costs did not have proper evidence of approval maintained. Lastly, time and effort was not supported for one transaction for the amount charged to the grant. Context: Of the general disbursement population, $121,199 of general disbursements were booked via unsupported journal entry (allocated). Of the payroll and fringe benefit disbursement population, $120,483 were booked via unsupported journal entry (allocated). Lastly, one of the forty payroll transactions tested did not agree to the amount charged to the grant. Questioned Costs: $241,682 Cause: Internal controls surrounding allocations were not properly designed and implemented and an audit trail for allocation journal entries/source documentation was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over allocations provides an opportunity for noncompliance and errors. Repeat Finding: Yes Recommendation: We recommend that the Organization design, implement and monitor internal controls over allocations as well as maintain source documentation to support amounts charged to the grant. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
2022-003 Allowable Costs – Payroll, Fringe, and General Disbursements Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Allowable costs must be approved by the awarding agency (2 CFR section 200.407) and necessary and reasonable for the performance of the federal award and allocable under the principles of 2 CFR, Subpart E. Additionally, costs must be adequately documented. Condition: Direct costs incurred were allocated through journal entries to the grant without support of an allocation methodology. Management was unable to provide an understanding of how to trace the allocated amounts to a consistent methodology or to original source documentation. Additionally, credit card costs did not have proper evidence of approval maintained. Lastly, time and effort was not supported for one transaction for the amount charged to the grant. Context: Of the general disbursement population, $121,199 of general disbursements were booked via unsupported journal entry (allocated). Of the payroll and fringe benefit disbursement population, $120,483 were booked via unsupported journal entry (allocated). Lastly, one of the forty payroll transactions tested did not agree to the amount charged to the grant. Questioned Costs: $241,682 Cause: Internal controls surrounding allocations were not properly designed and implemented and an audit trail for allocation journal entries/source documentation was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over allocations provides an opportunity for noncompliance and errors. Repeat Finding: Yes Recommendation: We recommend that the Organization design, implement and monitor internal controls over allocations as well as maintain source documentation to support amounts charged to the grant. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
2022-003 Allowable Costs – Payroll, Fringe, and General Disbursements Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Allowable costs must be approved by the awarding agency (2 CFR section 200.407) and necessary and reasonable for the performance of the federal award and allocable under the principles of 2 CFR, Subpart E. Additionally, costs must be adequately documented. Condition: Direct costs incurred were allocated through journal entries to the grant without support of an allocation methodology. Management was unable to provide an understanding of how to trace the allocated amounts to a consistent methodology or to original source documentation. Additionally, credit card costs did not have proper evidence of approval maintained. Lastly, time and effort was not supported for one transaction for the amount charged to the grant. Context: Of the general disbursement population, $121,199 of general disbursements were booked via unsupported journal entry (allocated). Of the payroll and fringe benefit disbursement population, $120,483 were booked via unsupported journal entry (allocated). Lastly, one of the forty payroll transactions tested did not agree to the amount charged to the grant. Questioned Costs: $241,682 Cause: Internal controls surrounding allocations were not properly designed and implemented and an audit trail for allocation journal entries/source documentation was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over allocations provides an opportunity for noncompliance and errors. Repeat Finding: Yes Recommendation: We recommend that the Organization design, implement and monitor internal controls over allocations as well as maintain source documentation to support amounts charged to the grant. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
Finding 2022-001: Inadequate internal controls over grant reporting Type of Finding: Significant Deficiency Condition: Reporting of grant income and expenditures to the federal award agency did not have the proper controls in place to detect and prevent inaccurate amounts. Criteria: 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 Sponsoring Organizations of the Treadway Commission (COSO). Cause: Internal controls were inadequate over the grant reporting process. Effect: Reporting under the Appalachian Regional Commission grant was not accurate and overreported expenditures. Recommendation: Procedures should be implemented requiring an individual to perform a secondary review of grant reporting and supporting documentation prior to submission. Views of Responsible Officials and Planned Corrective Actions: PRIDE agrees with the finding and recommended procedures will be implemented.
Finding 2022-004: Activities Allowed and Unallowed, Allowable Costs (Compliance; Internal Controls Over Compliance) Material Weakness Criteria: Uniform Guidance 2 CFR, Part §200.303(a) requires that non-federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 School District received and expended section 7007 Construction Impact Aid. According to program specific compliance requirements, the School District must use these funds for construction as defined in Section 7013(3) of the Elementary and Secondary Education Act. Under Section 7013(3), the term "construction" includes (a) preparing drawings and specifications for school facilities; (b) erecting, building, acquiring, altering, remodeling, repairing, or extending school facilities; (c) inspecting and supervising the construction of school facilities; and (d) debt servicing for such activities (sections 7007 and 7013(3) of ESEA (20 USC 7707 and 7713)). Condition: During the review of the School’s internal controls related to Impact Aid expenditures, a sample of 67 transactions was tested for both control effectiveness and compliance. The School did not provide evidence of appropriate approval for any of the transactions selected for control testing. In addition, none of the transactions selected for compliance testing included proper supporting invoice documentation. As a result, alternative audit procedures were performed, including direct confirmations to Dick Anderson Construction and Cushing Terrell. Through these confirmations, expenditures totaling $2,415,667.01 and $313,682.20, respectively, were confirmed. Questioned Costs: Known = $645,081.79 Cause: The School District does not have established internal control policies and procedures to ensure appropriate supporting documentation and approvals are obtained prior to the disbursements being processed. Effect: The School District is not in compliance with Activities Allowed and Unallowed and Allowable Costs compliance requirements for the Impact Aid major program. This could lead to sanctions by the funding agencies. Recommendation: We recommend the School District become familiar with requirements of 2 CFR, Part §200.303(a) and establish appropriate internal control policies and procedures and that all staff be trained on those policies and procedures so they are familiar with the requirements. We further recommend the School District does not process payment for disbursements that do not contain sufficient, appropriate supporting documentation and necessary approvals. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.
Condition: During the process of documenting the County’s internal controls regarding federal disbursements, we noted that Osage County has not established procedures to ensure compliance with the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; 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 to grant requirements and could lead to a loss of federal funds to the County. Recommendation: OSAI recommends the County gain an understanding of grant requirements for these programs and implement internal control procedures to ensure compliance with grant requirements. Management Response: Chairman of the Board of County Commissioners: The lack of cooperation and oversight during the prior County Clerk’s administration left significant gaps that required immediate attention. The current leadership has made addressing these gaps a top priority. Together, we are: • meeting monthly to update procedures and build stronger internal controls, • developing and formalizing policies to ensure full compliance with federal grant requirements, • and improving communication between offices to ensure federal reporting is accurate and timely. Our collective commitment is to put permanent measures in place to prevent these issues from recurring and to uphold the highest level of compliance for all federal programs. County Clerk: I was not the County Clerk in office at this time. The County will comply with all aspects of grant reporting and requirements. The Officials will work together to put policies and procedures in place to ensure more accurate reporting. County Treasurer: The County Officers will work on better communication to more accurately report the SEFA funds. Criteria: 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). Further, 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. 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.
Federal Agency: Department of the Interior Federal Programs: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Numbers: 15.027 Federal Award Identification Number and Year: A19AP00118-09 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters Criteria: In accordance with 2 CFR 200.303, the College must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the College is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)). Further 200.313(d)(2) states that the property records must be reconciled with a physical inventory count at least once every two years. Condition: The College did not have documentation of physical inventory of the equipment purchased with Federal Funds. The College did not adequately track equipment funded with federal awards and their respective disposals. Further the College did not maintain the required information as part of their property and equipment records. Questioned Costs: None Context: During our testing of property and equipment purchases it was noted the property records for the equipment purchased did not contain the required information for all 11 equipment purchases we selected for testing. In addition, there was no documentation that showed a physical inventory was taken over this equipment at least every two years. Cause: The College did not have an effective control in place to ensure that the required information for equipment purchased with federal funds was maintained and that a physical inventory count was completed every two years. Effect: The College did not meet equipment property record requirements for equipment purchased with federal funds. Repeat Finding: Yes, see Finding 2021-004. Recommendation: We recommend the College implement policies and procedures to ensure all property and equipment purchased with federal funds includes such information in the property records to comply with the requirement, and physical inventory be taken at least every two years. Views of Responsible Officials: Management agrees with the finding and has prepared a plan to correct the finding.
Federal Agency: Department of Education Federal Programs: COVID-19 – Education Stabilization Fund Assistance Listing Numbers: 84.425E Federal Award Identification Number and Year: P425E200449 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance Criteria: In accordance with 2 CFR 200.303, the College must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the College is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The College did not have observable controls to test to ensure the students receiving HEERF funding were eligible. Questioned Costs: None. Context: During the testing of student disbursements, we were unable to test a specific control in place to ensure any error in a student’s disbursement would be prevented and detected in a timely manner. Cause: The College did not have an observable control in place to ensure students were eligible for the HEERF funding they received. Effect: It is possible that a student could receive funding when they are not eligible for. Repeat Finding: No. Recommendation: We recommend the College retain evidence of the review of student accounts prior to disbursement of HEERF funds. Views of Responsible Officials: Management agrees with the finding and has prepared a plan to correct the finding.
Federal Agency: Department of the Interior and Department of Education Federal Programs: Assistance to Tribally Controlled Community Colleges and Universities and COVID-19 – Education Stabilization Fund Assistance Listing Numbers: 15.027 and 84.425K Federal Award Identification Number and Year: A19AP00118-09 and P425K00022 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Uniform Guidance Cost Principles described in 2 CFR Part 200, Compensation, states that costs of compensation are allowable to the extent that they satisfy the specific requirements of the grant and that total compensation for individual employees is reasonable for the services rendered. Salaries and benefits are allowable for this grant as long as the job duties are a result of responding to the pandemic. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted the following matters related to allowable costs and activities. Assistance Listing Number 15.027: • Of the 14 payroll disbursements selected for testing, it was noted that 6 employees were underpaid and 5 were overpaid based on the information available. Assistance Listing Number 84.425K: • Of the 60 payroll disbursements selected for testing, it was noted that one employee was overpaid based on the information available. Questioned Costs: Assistance Listing Number 15.027 - $6,649. Context: During our testing of payroll expenditures, the College was unable to provide support for payroll costs charged to the grant. Total payroll costs charged to assistance listing numbers 15.027 was $3,920,538. Total payroll costs charged to assistance listing number 84.425K and 84.425F were $836,137.78. Cause: Due to staffing shortages, as well as the amount of time passed from the transactions being tested, the College was unable to provide support for payroll costs. Effect: The College is unable to support payment amounts to 12 employees. Repeat Finding: Yes, see Finding 2021-005 Recommendation: We recommend the College enhance their controls around payroll disbursements to ensure employees are paid properly. Views of Responsible Officials: Management agrees with the finding and has prepared a plan to correct the finding.
Federal Agency: Department of Education Federal Programs: COVID-19 – Education Stabilization Fund Assistance Listing Numbers: 84.425E, 84.425F, 84.425K Federal Award Identification Number and Year: P425E200449, P425F204781, P425K200022 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Funds (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: The College is not in compliance with Quarterly and Annual reporting requirements for HEERF. Questioned Costs: None. Context: Out of 2 Quarterly Institutional and 2 Quarterly Student reports tested all 4 reports were not submitted timely. In addition, the annual report was not submitted timely. Cause: The College did not have appropriate controls in place to ensure reports were completed and published to the institution’s website in a timely manner. Effect: The institution is not meeting the reporting and information-sharing requirements determined by the Department of Education. As a result, the institution may be subject to additional enforcement actions by the Department of Education including a delay in funding for additional HEERF programs and possibly being determined ineligible for other program funding. Repeat Finding: No. Recommendation: We recommend the College review the reporting requirements and implement procedures to ensure that all required reports are issued/posted in an accurate and timely manner. Views of Responsible Officials: Management agrees with the finding and has prepared a plan to correct the finding.
Federal Agency: Department of Health and Human Services Federal Programs: Research and Development Cluster Assistance Listing Numbers: 93.859 Federal Award Identification Number and Year: 1S06GM123552-01 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not make payments to subrecipients within 30 days after receipt of invoices. Questioned Costs: None. Context: During our testing of 7 out of 27 subrecipient payments during the year. CLA notes that 1 of the 7 payments was not made to the subrecipient within 30 calendar days as required. Cause: The College did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The College was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: No. Recommendation: We recommend that the College review and update current procedures to ensure subrecipient payments are paid timely. Views of Responsible Officials: Management agrees with the finding and has prepared a plan to correct the finding.
Federal Agency: Department of the Interior, National Science Foundation, Department of Health and Human Services, and Department of Education Federal Programs: Assistance to Tribally Controlled Community Colleges and Universities, Research and Development Cluster and COVID-19 – Education Stabilization Fund Assistance Listing Numbers: 15.027, 47.076 and 93.859, and 84.425K and 84.425F Federal Award Identification Number and Year: Various Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters Criteria: In accordance with 2 CFR 200.303, the College must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the College is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition: 10 out of the 11 vendors tested had no documentation to ensure the vendor was not suspended or debarred at the time of purchase. At least one vendor was tested from each program. Upon Inquiry, we noted the College does not have a suspension and debarment policy or process. Questioned Costs: None. Context: The College entered into transactions with vendors before verifying they were not suspended or debarred. Cause: There is no control system in place to ensure there are no transactions entered into with suspended or debarred vendors. Effect: The College could have entered into transactions with suspended or debarred vendors. Repeat Finding: Yes, see Finding 2021-003. Recommendation: We recommend the College implement a suspension and debarment policy and corresponding procedures. Views of Responsible Officials: Management agrees with the finding and has prepared a plan to correct the finding.
Finding 2022-008 – Lack of Internal Controls Over Major Federal Programs – Disaster Grants – Public Assistance (Presidentially Declared Disasters) (Repeat Finding 2017-014, 2018-005, 2020-007) PASS-THROUGH GRANTOR: Oklahoma Department of Emergency Management FEDERAL AGENCY: U.S. Department of Homeland Security ASSISTANCE LISTING: 97.036 FEDERAL PROGRAM NAME: Disaster Grants – Public Assistance (Presidentially Declared Disasters) FEDERAL AWARD NUMBER: DR-4438, DR-4315, and DR-4575 FEDERAL AWARD YEAR: 2022 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions QUESTIONED COSTS: $-0- Condition: During the process of documenting the County’s internal controls regarding federal disbursements, we noted that the County has not established procedures to ensure compliance with the following requirements: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions. 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 resulted in noncompliance with grant requirements and could lead to a 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 requirements. Management Response: Chairman of the Board of County Commissioners: The County will include discussion of all required compliance requirements for each federal program presented in our Officers’ meetings. District 1 County Commissioner: There are numerous external controls associated with federal funding, including oversight from both state and federal agencies. Internally, we have encountered resistance from certain county officials who are less familiar with the scope and structure of large federal projects. This included a former official who repeatedly asserted that “$400,000.00 is missing,” despite being shown conclusively that no funds were missing. That official resigned shortly thereafter. Incidents of this nature have made it more difficult to engage in productive discussions regarding internal controls. Nonetheless, I remain willing to meet openly and discuss internal controls in a transparent and constructive manner. Auditor Response: Uniform Guidance and GAO Standards require internal controls to be designed and implemented for all federal grant expenditures. 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). Further, 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.
Finding 2022-009 – Lack of Internal Controls Over the SEFA and Noncompliance with Compliance Requirements Over Major Federal Programs – FEMA (Repeat Finding – 2018-006, 2020-008) PASS-THROUGH GRANTOR: Oklahoma Department of Emergency Management FEDERAL AGENCY: U.S. Department of Homeland Security ASSISTANCE LISTING: 97.036 FEDERAL PROGRAM NAME: Disaster Grants – Public Assistance (Presidentially Declared Disasters) FEDERAL AWARD NUMBER: DR-4438, DR-4315, and DR-4575 FEDERAL AWARD YEAR: 2022 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions QUESTIONED COSTS: $1,170,296 Condition: Upon inquiry of District 1 staff and review of documentation and compliance procedures for ALN 97.036, the following items were noted: • Due to scope limitations placed on the audit, auditors were unable to access records and the ability to communicate with District 1 employees was restricted. • Documents provided to the auditors could not be reconciled to the amounts reported on the Schedule of Expenditures of Federal Awards (SEFA). • District 1 does not print or certify any expense reports; therefore, any supporting documentation was not reviewed when reporting federal expenditures to the County Clerk. • District 1 was unable to meet the deadlines set by themselves, as it took nine months for the County to provide limited documentation for federal projects. • Federal expenditures could not be tested due to inadequate implementation of policies and procedures regarding the reporting and retention of federal expense documentation. Cause of Condition: Policies and procedures have not been designed and implemented to ensure accurate reporting on the County’s SEFA, and to ensure federal expenditures are made in accordance with federal compliance requirements. Effect of Condition: These conditions resulted in noncompliance with grant requirements and could result in loss of federal funds to the County. Recommendation: OSAI recommends the County gain an understanding of the compliance requirements for federal programs and implement internal control procedures to ensure compliance with all requirements. Further, we recommend all documentation be properly maintained for inspection and ensure accurate reporting on the County’s SEFA. Management Response: Chairman of the Board of County Commissioners: The County will make sure that all federal documentation is maintained by each district for inspection and will ensure it is accurately reported on the SEFA. District 1 County Commissioner: All work associated with the projects referenced in Audit Finding 2020-005 was completed in accordance with FEMA requirements. The work was fully documented, and final results were physically inspected on site by Oklahoma Emergency Management (OEM) personnel. Both OEM and FEMA reviewed and accepted the work performed and the supporting documentation, as evidenced by the county’s reimbursement for the completed projects. FEMA reimbursement would not have occurred had the work or documentation been deficient. Auditors initially indicated that documentation was required for FEMA Event 4315 only. Subsequently, the scope of the request was expanded to include “all events” without a clear written explanation or formal notification of the expanded scope. Following an on-site visit to the county barn for a tabletop discussion, the auditor sent an email dated May 11, 2023, identifying specific projects for which documentation was reportedly still needed. The projects later cited in Audit Finding 2020-05 were not included in that list. On June 12, 2023, the auditor emailed stating: “I believe I have documents for every project except 4575.203.454750 and 4575.203.454831 (Disaster. Project Worksheet.Site).” The requested documentation was provided promptly, and the auditor acknowledged receipt. He subsequently sent several clarifying questions and, in a final email dated June 20, 2023, stated that he would consult with his team and follow up as needed. No further communication was received from the auditor. or any member of the auditor’s office requesting additional documentation. Nearly three years have elapsed without follow-up. The County does have documentation for all projects listed in the audit finding, and these records were provided to auditors during their on-site visits to the county barn. Auditor Response: District 1 did not comply with all requirements of the federal grant including, but not limited to, providing documentation for audit purposes and preparing accurate and reconciled reports. The required documentation to support the FEMA expenditures were not provided to the auditors. Physical inspections by FEMA or OEM do not constitute an audit under Uniform Guidance. An audit includes examining all supporting documentation to ensure the County complied with all the compliance requirements required by Uniform Guidance. Maintaining adequate documentation to support federal grant expenditures is critical for the County to comply with federal compliance requirements. 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). Title 2 CFR § 200.318 (a), General procurement standards, reads as follows: The recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in 200.317 through 200.327. Title 2 CFR § 200.84 Questioned Cost reads as follows: Questioned cost means a cost that is questioned by the auditor because of an audit finding: (a) Which resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for fund used to match Federal funds; (b) Where the costs, at the time of the audit, are not supported by adequate documentation; or (c) Where the costs incurred appear unreasonable and do not reflect the actions a prudent person would take in the circumstances. 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. [….] The limitations of the auditor are described in the American Institute of Certified Public Accountants Clarified Statements on Auditing Standards AU-C § 210, which states, in part: “The concept of an independent audit requires that the auditor's role does not involve assuming management's responsibility for the preparation and fair presentation of the financial statements or assuming responsibility for the entity's related internal control and that the auditor has a reasonable expectation of obtaining the information necessary for the audit insofar as management is able to provide or procure it. Accordingly, the premise is fundamental to the conduct of an independent audit.”
Finding 2022.006: Cash Management - Material Weakness Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS26638 - 2022 and 2023, H8DCS35487 - 2021, and H8F40829 - 2023 Criteria In accordance with §200.305, Federal Payment, grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect or Potential Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 9 drawdowns for testing of cash management. We noted there was no formal approval or evidence of review for all 9 drawdowns. Identification of Repeat Finding Yes, see finding 2021-006. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
MATERIAL WEAKNESSES 2022-003 - Allowable Costs/Cost Principles Federal Program Information: ALN - 10.760 - Water and Waste Disposal Systems for Rural Communities Criteria: The following CFR(s) apply to this finding: 2 CRF 200.303 Condition: During audit procedures, it was identified that the Town does not have invoices and board warrants approved before issuing checks. Cause: The Town does not have the necessary internal controls over compliance. Effect: Expenses may not be properly allocated to the grant; this could result in unallowable expenses being charged and subsequently improperly reimbursed by federal funds Identification of Questioned Costs: None identified. Context: The sample selection consisted of 5 out of 9 transactions. Of the 5 samples, 5 did not have consistent documented approval of invoices and board warrants to ensure that only allowable costs were being charged to the program and 2 out of 5 invoices were paid over 30 days late. Repeat Finding: This is a repeat finding of 2021-003 Recommendation: It is recommended that the Town develop and implement policies and procedures for documented approval process to ensure that only allowable costs are charged to the program. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding, and a version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the Town of Livermore Falls.
MATERIAL WEAKNESS 2022-006 - Allowable Costs/Cost Principles Federal Program Information: ALN - 66.458 - Clean Water State Revolving Funds Criteria: The following CFR(s) apply to this finding: 2 CRF 200.303 Condition: During audit procedures, it was identified that the Town does not have invoices and board warrants approved before issuing checks. Cause: The Town does not have the necessary internal controls over compliance. Lack of supervisory oversight. Effect: Expenses may not be properly allocated to the grant; this could result in unallowable expenses being charged and subsequently improperly reimbursed by federal funds. Identification of Questioned Costs: None identified. Context: The population consisted of 13 out of 39 transactions. The Town did not have consistent documented approval of invoices and board warrants to ensure that only allowable costs were being charged to the program. 2 out of 13 invoices were paid over 30 days late. Repeat Finding: This is a repeat finding of 2021-005. Recommendation: It is recommended that the Town develop and implement policies and procedures for documented approval process to ensure that only allowable costs are charged to the program. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding, and a version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the Town of Livermore Falls.
MATERIAL WEAKNESSES 2022-005 - Allowable Costs/Cost Principles Federal Program Information: ALN - 21.027 - Coronavirus State & Local Fiscal Recovery Funds Criteria: The following CFR(s) apply to this finding: 2 CRF 200.303 Condition: During audit procedures, it was identified that the Town does not have invoices and board warrants approved before issuing checks. Cause: The Town does not have the necessary internal controls over compliance. Lack of supervisory oversight. Effect: Expenses may not be properly allocated to the grant; this could result in unallowable expenses being charged and subsequently improperly reimbursed by federal funds Identification of Questioned Costs: None identified. Context: The population consisted of 2 out of 2 transactions. The Town did not have consistent documented approval of invoices and board warrants to ensure that only allowable costs were being charged to the program. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the Town develop and implement policies and procedures for documented approval process to ensure that only allowable costs are charged to the program. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding, and a version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the Town of Livermore Falls.
Federal Agency: Department of Housing and Urban Development and Department of Veterans Affairs Federal Program Name: Emergency Solutions Grant Program and VA Homeless Providers Grant and Per Diem Program Assistance Listing Number: 14.231 and 64.024 Federal Award Identification Number and Year: E20DW37001-2022 and ODMH543-1306-659-PD-21 Pass-Through Agency: North Carolina Department of Health and Human Services, Division of Aging and Adult Services Pass-Through Number(s): 00041416 Award Period: 7/29/2020 – 6/30/2022 and 10/1/2021 – 9/30/2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: In accordance with 2 CFR 200.302(b)(3), the recipient’s financial management system must maintain records sufficient to identify the amount, source, and expenditure of federal funds for federal awards, These records must contain information necessary to identify federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. In accordance with the Compliance Supplement, Part 6 – Internal Control, 2 CFR section 200.303 requires that non-Federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-Federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. In accordance with 2 CFR 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non- Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, when applicable. In accordance with 2 CFR 200.430(g), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records must: (1) Be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated, (2) Be incorporated into the official records of the recipient (3) Reasonably reflect the total activity for which the employee is compensated. Condition: During our testing, we noted the Organization did not have adequate controls to ensure that expenditures of federal awards were properly supported, reasonably reflective of the work performed, and properly reviewed and approved. Questioned costs: Assistance listing number: 14.231 Federal award identification number: E20DW37001-2022 Known questioned costs: $18,419 Assistance listing number: 64.024 Federal award identification number: ODMH543-1306-659-PD-21 Known questioned costs: $49,676 Context: During our testing, we noted the following related to the VA Homeless Providers Grant and Per Diem Program: 40 out of 40 payroll transactions tested for allowable costs and allowable activities were not allocated based on actual time worked on the grant and lacked adequate records. 11 out of 40 tested for allowable costs and allowable activities did not have evidence showingexpenditures were allowable under the grant. 17 out of 40 tested for allowable costs and allowable activities lacked evidence of review and approval. During our testing, we noted the following related to the Emergency Solutions Grant Program: 18 of 40 tested for allowable costs and allowable activities lacked evidence showing the expenditures were allowable under the grant. 8 out of 11 payroll transactions tested for allowable costs and allowable activities were not allocated based on actual time worked on the grant and lacked adequate records. Cause: The Organization’s controls were not sufficient to ensure that expenditures of federal funds were supported, reasonably reflecting the work performed under the program, reviewed and approved, and only for allowable costs and allowable activities. Effect: The Organization could have incurred expenses that were not allowable under the grant beyond those identified. Repeat Finding: Yes Recommendation: We recommend the Organization develop a system of internal controls to ensure that salaries and related payroll expenses are tracked to reasonably reflect the actual time spent working on the programs. In addition we recommend that management retain all documents including evidence of review and approval for all expenditures of federal funds until the latter of the legally required retention period or completion of required audits. Views of responsible officials: There is no disagreement with the audit finding.