PASS-THROUGH GRANTOR: Oklahoma Department of Emergency Management; Oklahoma Office and Management and Enterprise Services FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.019 FEDERAL PROGRAM NAME: Coronavirus Relief Fund FEDERAL AWARD NUMBER: Oklahoma CARES PPE; SA-2242 FEDERAL AWARD YEAR: 2020 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Costs Principles; and Period of Performance QUESTIONED COSTS: $868,053 Condition: The County submitted and received reimbursement for $1,269,227 in expenditures related to the COVID-19 Pandemic. After performing testwork on 100% of the County’s expenditures, $868,053 was not expended in accordance with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance due to ineligible costs. • The County was reimbursed $783,766 for payroll expenditures for the OCCJA for the period of March 2020, through August 2020. The reimbursement of these funds was determined to be unallowable, as these costs were not expenditures of the County. • The County was reimbursed $71,376 for General Government payroll expenditures for multiple county employees. The reimbursement of these funds was determined to be unallowable as these were not expenditures to mitigate or prevent the spread of COVID-19 as required by the grant agreement. • The County was reimbursed $12,500 in payroll expenditures for the County’s Emergency Management Department. The reimbursement of these funds was determined to be unallowable, as these costs were previously reimbursed or will be reimbursed by another federal program. • The County was reimbursed for $411 in costs that the County could not provide documentation to support the expenditures. • The County relied on the Oklahoma Office of Management and Enterprise Services to ensure that the County reimbursement request was for eligible expenditures. Cause of Condition: Policies and procedures have not been designed and implemented to ensure that the County has proper internal controls over federal grant expenditures and that the expenditures were for an allowable cost. Effect of Condition: These conditions resulted in noncompliance with federal grant requirements. The County runs the risk of misappropriation of funds which could hinder the County from receiving future federal funding. Further, these conditions could result in the repayment of funds. Recommendation: OSAI recommends the County gain an understanding of requirements for this program and design and implement policies and procedures to ensure compliance with all applicable grant requirements. Management Response: District 1 County Commissioner: My tenure as an Okmulgee County Commissioner began, October 3, 2022. My understanding is Okmulgee County relied on the State of Oklahoma Office of Management and Enterprise Services (OMES) as the overseer of eligible expenditures. OMES approved the expenditures for reimbursement. District 2 County Commissioner: I did not take office until January of 2021, months after the County had submitted expenditures for reimbursement from the Coronavirus Relief Fund and my understanding of the submission process is that the County sent all reimbursement documentation to OMES, who were responsible for vetting the submissions. All submission made by Okmulgee County to OMES were approved and reimbursed by OMES. District 3 County Commissioner: I took office January 3, 2023, I will work with other officials to design and implement policies and procedures to ensure compliance with all applicable grant requirements. Criteria: Title 42 United States Code § 801 – Coronavirus relief fund Section 801(d) requires the States, Tribal governments, or units of local government use the funds received to cover only those costs that (1) are necessary expenditures incurred due to the public health emergency with respect to the Coronavirus Disease 2019 (COVID-19); (2) were not accounted for in the budget most recently approved as of March 27, 2020, for the State or government; and (3) were incurred during the period that begins on March 1, 2020, and ends on December 30, 2020. Additionally, 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 § 200.403 - Factors affecting allowability costs states in relevant part, Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. (g) Be adequately documented.
Department of Health and Human Services Federal Assistance Listing/CFDA #93.498 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 1 TIN #730929722 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting Material Weakness in Internal Control Over Compliance and Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The total lost revenues included on the report submitted to the Health Resources and Services Administration (HRSA) for Period 1 (Period 1 Report) utilizing Option 1, as defined by HRSA, contained errors. Accordingly, the exclusion of clinic revenue and the exclusion of the cost report estimate adjustment in the lost revenue calculation spreadsheet were not identified by management. Cause: The Hospital did not have an internal control process in place to ensure the calculation of lost revenues was reviewed and approved. Accordingly, the errors in the lost revenue calculation spreadsheet were not identified by management. In addition, the Hospital did not have an internal control process in place to ensure a review and approval of the Period 1 Report was performed by someone other than the preparer of the report. Effect: The lost revenue reported to HRSA for Period 1 was understated. Questioned Costs: None. The Hospital’s lost revenues for Period 1 were understated. Context: All 10 line items associated with the Option 1 lost revenue calculation were tested. There were errors noted in all line items tested. The lost revenues included on the Period 1 Report totaled $2,917,668 but should have been $3,377,089 for a difference of $459,421. Repeat Finding from Prior Years: No Recommendation: We recommend the Hospital implement a control process which includes a documented secondary review and approval of required reports to be submitted to the federal agency prior to submission. The Hospital’s processes should also be amended to ensure the lost revenue calculation not only agrees with system generated reports but is accurately calculated and has a documented secondary review and approval. Views of Responsible Officials: Management agrees with the finding
Department of Health and Human Services Federal Assistance Listing/CFDA #93.498 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 1 TIN #730929722 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting Material Weakness in Internal Control Over Compliance and Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Hospital claimed expenditures that were not incurred during the reporting period. These expenditures were identified as unallowed on the Hospital’s schedule of expenditures, but inadvertently included in the amounts ultimately reported on the Period 1 report to HHS. Cause: The Hospital did not have an adequate internal control process in place to ensure expenditures claimed were being in the proper period. The Hospital also did not have a control to ensure the reporting was reviewed and approved by someone other than the preparer. Effect: The Hospital claimed and reported expenditures in the incorrect reporting period. Questioned Costs: None. While there were $240,637 of expenditures considered to be reported in the incorrect reporting period, the Hospital had excess lost revenues of $268,046 and additional underreported lost revenues of $459,421, which covers the error. Context: We sampled 60 of 382 expenditure transactions. We noted five selections resulting in a specific error totaling $240,637. Upon discovery of the error, we reviewed all purchase dates of expenditures to ensure no additional expenditures were outside the reporting period. Repeat Finding from Prior Years: No Recommendation: We recommend the Hospital create an internal control policy to ensure expenditures are reported in the correct period. Views of Responsible Officials: Management agrees with the finding.
Department of Health and Human Services Views of Responsible Officials: Management agrees with the finding. Federal Assistance Listing/CFDA #93.498 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 1 TIN #730929722 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting Material Weakness in Internal Control Over Compliance and Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Hospital is a critical access hospital and reimbursed from Medicare based on the expenses incurred to treat Medicare beneficiaries for the majority of operating activities. The Hospital claimed expenses attributable to coronavirus but did not reduce such expense by the amounts Medicare reimburses or is obligated to reimburse the Hospital or amounts reimbursed by other grants. Cause: The Hospital did not have an adequate internal control policy in place to ensure expenses claimed were being reduced by Medicare's reimbursement or claimed on other grants. The Hospital also did not have a control to ensure the reporting was reviewed and approved by someone other than the preparer. Effect: The Center claimed and reported expenses that were reimbursed or obligated to be reimbursed by Medicare or other grants. Questioned Costs: None. While there were $308,355 of expenses considered to be reimbursed by other sources, the Hospital had excess lost revenues of $268,046 and additional underreported lost revenues of $459,421, which covers the error. Context: We sampled 60 of 382 expenditure transactions. Excluding the five transactions noted in Finding 2021-006, errors were identified in all other selections. The Hospital estimated that Medicare reimburses approximately 28.92% of expenses reported on annual cost reports based on its 2021 filed cost report. The reimbursement percentage was then applied to the entire population of allowable expenses. In addition, one transaction was identified that was also reimbursed by another federal grant. Repeat Finding from Prior Years: No Recommendation: We recommend the Hospital modify internal control policies to ensure amounts claimed for this program are reduced by amounts reimbursed or obligated to be reimbursed by another source, including Medicare cost-based reimbursement. Views of Responsible Officials: Management agrees with the finding.
Department of Health and Human Services Federal Assistance Listing/CFDA #93.498 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 1 TIN #730929722 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting Material Weakness in Internal Control Over Compliance and Noncompliance Not Considered Material Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The total eligible expenses included on the Period 1 Report did not agree with the underlying supporting schedules. In addition, there were errors identified in the underlying supporting schedules. Cause: The Hospital did not have an adequate internal control policy in place to ensure a review and approval of the Period 1 Report was performed by someone other than the preparer of the report. Effect: The Hospital claimed eligible expenditures that were not supportable. Questioned Costs: None. While there was an overstatement of allowable expenses of $19,356, the Hospital had excess lost revenues of $268,046 and additional underreported lost revenues of $459,421, which covers the error. Context: Sampling was not used. We tested the key line item related to Other PRF Expenditures in identifying the error. Repeat Finding from Prior Years: No Recommendation: We recommend the Hospital implement a control process which includes a documented secondary review and approval of required reports to be submitted to the federal agency prior to submission. In addition, we recommend the report be based upon supporting schedules that also includes a documented secondary review and approval. Any expenses claimed for the federal program should be calculated correctly and have adequate supporting documentation. Views of Responsible Officials: Management agrees with the finding.
2021-007 Lack of Documentation to Support Distribution of Wages (Significant Deficiency) Federal Agency: Department of Education Pass-through Agency: New Hampshire Department of Education Cluster/Program: Education Stabilization Fund Assistance Listing Numbers: 84.425D Passed-through Identification: #20204815 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding: Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement: Federal regulations 2 CFR 200.303 states, the district, as a recipient of Federal funds, must establish and maintain effective internal controls 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. In addition, under 2 CFR 200.430, it states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, (2) be incorporated into the official records of the non-Federal entity, (3) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, and (4) support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award or a federal award and non-Federal award. Condition: During our review of payroll charged to the grant, we noted one employee who did not have documentation to support the distribution of the employee’s time spent on grant activities. Cause: Administrative oversight. Effect: The District did not have adequate documentation to support the distribution of the employee’s wages paid using grant funds. Questioned Costs: $3,136 Repeat Finding: No Recommendation: We recommend that documentation be retained to support the distribution of salaries and wages for all employees paid using grant funds. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
Assistance Listing Number, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services, COVID-19 - Provider Relief Fund Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - In accordance with 2 CFR 200.303, the System must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The reporting requirements for PRF targeted distributions required the recipient entity to report on the use of the funds. Condition - The System received targeted distributions for Bucyrus Community Hospital. A period one portal submission was completed, but no allowable expenses or lost revenues were reported within the Bucyrus Community Hospital report. All allowable expenses and lost revenues were reported on the first period portal submission for Galion Community Hospital, another hospital of the Avita Health System. Questioned Costs - None Identification of How Questioned Costs Were Computed - Lost revenues related to the targeted distributions of $3,878,983 received by Bucyrus Community Hospital were reported within the Galion Community Hospital period 1 portal submission. Context - Galion Community Hospital and Bucyrus Community Hospital received targeted distributions during period one. The allowable expenses and lost revenues related to the Galion Community Hospital targeted distributions were reported within the recipient entities portal submission, while there were no allowable expenses or lost revenues reported within the Bucyrus Community Hospital period one portal submission. The total lost revenue reported in the Galion Community Hospital period one portal submission was sufficient to cover all period one funding. Cause and Effect - The System failed to review all reporting requirements, which caused the System to fail to report allowable expenses and lost revenues within the portal submission for the specific entity that received targeted PRF. Recommendation - The System should adequately review all applicable reporting requirements for federal funding received. Views of Responsible Officials and Planned Corrective Actions - The portal submission could not be modified by the time we identified the reporting issue. As such, no corrective report was completed, however management will implement procedures to ensure reporting requirements are adequately reviewed for all federal funding.
2021-001 – Internal Controls over Allowable Costs Identification of the Federal Program: 93.498 COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution 21.019 COVID-19 - Coronavirus Relief Fund Criteria: In accordance with 2 CFR Section 200.303, non-Federal entities must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: In accordance with established internal controls, Chesapeake Hospital Authority (the Authority) did not maintain documentation evidencing that costs were approved prior to charging the federal program. Cause: Due to the initial or early years of the Federal awards, internal controls over compliance and identification of costs allowable under the Federal award did not operate as designed in certain transactions. Effect: Approval of allowable charges relating to non-salary transactions reported to the federal awarding agency via the Health Resources & Services Administration (HRSA) Provider Relief Fund Portal may not have been adequately documented. Questioned costs: None Context: We selected 25 non-payroll costs charged to the 93.498 federal award and reported under the “Other PRF Expenses” section of the HRSA Provider Relief Fund Portal submission and 23 non-payroll costs charged to the 21.019 federal award. All costs selected in such testing were noted as allowable, however were unable to be supported by documentation of approval for charging to the federal program. Repeat finding: No Recommendation: We recommend the Authority enforce policies and procedures over document retention for approval of costs permitting charge to the federal program. View of Responsible Officials: The Authority’s management agrees with the federal award finding identified in the audit. Management’s response to this finding is described in the accompanying management’s corrective action plan.
2021-001 – Internal Controls over Allowable Costs Identification of the Federal Program: 93.498 COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution 21.019 COVID-19 - Coronavirus Relief Fund Criteria: In accordance with 2 CFR Section 200.303, non-Federal entities must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: In accordance with established internal controls, Chesapeake Hospital Authority (the Authority) did not maintain documentation evidencing that costs were approved prior to charging the federal program. Cause: Due to the initial or early years of the Federal awards, internal controls over compliance and identification of costs allowable under the Federal award did not operate as designed in certain transactions. Effect: Approval of allowable charges relating to non-salary transactions reported to the federal awarding agency via the Health Resources & Services Administration (HRSA) Provider Relief Fund Portal may not have been adequately documented. Questioned costs: None Context: We selected 25 non-payroll costs charged to the 93.498 federal award and reported under the “Other PRF Expenses” section of the HRSA Provider Relief Fund Portal submission and 23 non-payroll costs charged to the 21.019 federal award. All costs selected in such testing were noted as allowable, however were unable to be supported by documentation of approval for charging to the federal program. Repeat finding: No Recommendation: We recommend the Authority enforce policies and procedures over document retention for approval of costs permitting charge to the federal program. View of Responsible Officials: The Authority’s management agrees with the federal award finding identified in the audit. Management’s response to this finding is described in the accompanying management’s corrective action plan.
Federal Program: COVID-19: Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Program Assistance Listing Number: 93.498 Federal Agency: U.S. Department of Health and Human Services Award Number: N/A Award Year: 2020 Compliance Requirement: Reporting Questioned Costs: Not determinable Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which requires an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Recipients of Provider Relief Funds (PRF) payments must also comply with the reporting requirements described in the PRF terms and conditions and specified in directions issued by the U.S. Department of Health and Human Services. Condition and Context: The System did not complete the PRF Period 1 reporting in accordance with the U.S. Department of Health and Human Services guidance. The System did not enter the correct amounts from its data supporting lost revenues for all quarters; it also did not enter the correct amounts from its data supporting eligible expenditures. The adjustments needed within the PRF reports to correct the errors decreased year over year lost revenues from $21,664,944 to $11,771,346 and decreased eligible expenditures from $7,527,194 to $4,334,813, on total distributions of PRF funding of $14,972,846. In summary, the data supporting amounts for lost revenues and eligible expenses totals $16,104,159 on total distributions of PRF funding of $14,972,846 in this reporting period. Effect: The amounts reported to Health Resources & Services Administration (HRSA) were not in accordance with established U.S. Department of Health and Human Services reporting guidance. Cause: Errors in the lost revenues and eligible expenditures presented in the Period 1 report submissions were not detected by the Sytem's internal control process. Recommendation: We recommend that management implement procedures to ensure that the most recent guidance is reviewed and understood and that information used in preparation of the reports is reviewed, with errors addressed, prior to reporting. Planned Corrective Actions and View of Responsible Officials: System management agrees with the finding and has updated its lost revenue calculation. Management attempted to update lost revenue amounts with filing of its Period 4 reports; however, additional data entry errors were made.
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, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
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, 2020 to June 30, 2021 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, time and effort documentation for actual time incurred should be maintained for payroll charges to the grant. Context: Of the general disbursement population, $67,985 of general disbursements were booked via unsupported journal entry (allocated). Of the payroll and fringe benefit disbursement population, $87,777 were booked via unsupported journal entry (allocated). Questioned Costs: $155,762 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: N/A 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.
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, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
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, 2020 to June 30, 2021 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, time and effort documentation for actual time incurred should be maintained for payroll charges to the grant. Context: Of the general disbursement population, $67,985 of general disbursements were booked via unsupported journal entry (allocated). Of the payroll and fringe benefit disbursement population, $87,777 were booked via unsupported journal entry (allocated). Questioned Costs: $155,762 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: N/A 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.
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, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
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, 2020 to June 30, 2021 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, time and effort documentation for actual time incurred should be maintained for payroll charges to the grant. Context: Of the general disbursement population, $67,985 of general disbursements were booked via unsupported journal entry (allocated). Of the payroll and fringe benefit disbursement population, $87,777 were booked via unsupported journal entry (allocated). Questioned Costs: $155,762 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: N/A 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.
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, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
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, 2020 to June 30, 2021 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, time and effort documentation for actual time incurred should be maintained for payroll charges to the grant. Context: Of the general disbursement population, $67,985 of general disbursements were booked via unsupported journal entry (allocated). Of the payroll and fringe benefit disbursement population, $87,777 were booked via unsupported journal entry (allocated). Questioned Costs: $155,762 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: N/A 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.
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, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
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, 2020 to June 30, 2021 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, time and effort documentation for actual time incurred should be maintained for payroll charges to the grant. Context: Of the general disbursement population, $67,985 of general disbursements were booked via unsupported journal entry (allocated). Of the payroll and fringe benefit disbursement population, $87,777 were booked via unsupported journal entry (allocated). Questioned Costs: $155,762 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: N/A 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.
Federal Program - COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Program Assistance Listing Number - 93.498 Federal Agency - U.S. Department of Health and Human Services Passed-Through Entities - N/A Award Number - N/A Award Year - 2020 Compliance Requirement - Activities Allowed or Unallowed Questioned Costs - $1,359,809 Criteria - Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Provider Relief Funds (PRF) payments must be used for allowable expenses and lost revenue described in the PRF terms and conditions and specified in guidance issued by the U.S. Department of Health and Human Services. Activities allowed have been defined as expense used to prevent, prepare for, and respond to coronavirus, domestically or internationally, for necessary expenses to reimburse, through grants or other mechanisms, eligible health care providers for health care related expenses or lost revenues that are attributable to coronavirus. Additionally, all recipients of PRF payments must comply with the reporting requirements described in the PRF terms and conditions and specified in directions issued by the U.S. Department of Health and Human Services. Condition and Context - The Hospital included expenses in its filing that did not meet criteria of allowable expenses as defined by the U.S. Department of Health and Human Services guidance. The filing included various expenses associated with the facility that were not specifically used to prevent, prepare for, and respond to the coronavirus. During our testing we noted exceptions on 7 of 40 samples. Upon further analysis of the entire population, we noted that the Hospital reported expenses associated with the facility that were not specifically used to prevent, prepare for, and respond to the coronavirus totaling $1,359,809. The Hospital received distributions totaling $3,736,717 and reported total expenses of $1,950,653. Our sample was not a statistically valid sample. Effect - The Hospital claimed expenses that were not in accordance with established U.S. Department of Health and Human Services guidance and therefor deemed unallowable. Cause - The Hospital had an insufficient control in place to identify and correct errors prior to reporting on the use of their Provider Relief Funds. Recommendation - We recommend that management implement procedures to ensure that the most recent guidance is reviewed and understood and that information used in accumulating allowable expenses is reviewed, with errors addressed before completing any future filings. Procedures should be performed on a monthly basis with previously recognized expenses being reviewed to ensure they qualify as an allowable expense under the most recent guidance. View of Responsible Officials - Grafton City Hospital agrees with the finding.
2021-002 – Earmarking, Reporting (Performance Progress Reporting) Material Weakness in Internal Controls Over Compliance and Instance of Noncompliance (Scope Limitation) Assistance Listing Number: 16.589 Federal Agency/Pass-through Entity - Program Name: Department of Justice - Rural Domestic Violence, Dating Violence, Sexual Assault, Stalking Assistance Program Award Number: 2020-WR-AX-0041 Award Year(s): 2020-2023 Criteria or specific requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Grant Agreement Requirements - Earmarking Section 50 of the grant agreement requires that no more than 30% of project activities and grant funds will be dedicated to awareness and prevention activities. Grant Agreement Requirements – Performance Progress Reporting Section 35 of the grant agreement requires submission of semi-annual performance progress reports that describe activities conducted during the reporting period, including program effectiveness measures. 2 CFR Section 200.403(g) states that for costs to be allowed under Federal awards, they must be adequately documented and there must be sufficient documentation. Lastly, according to 2 CFR 200.1, Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Condition: The Coalition does not have controls in place to track actual expenditures related to the earmarking requirements in Section 50 of the grant award. The Coalition does have controls related to the review and approval of performance progress reports; however, it was noted that this control was not operating effectively to ensure proper document retention to support earmarking amounts reported. Questioned Costs: Questioned costs are not determinable. Context: We tested one semi-annual performance progress report required by Section 35 of the grant agreement. We noted that the Coalition reported 5% of grant expenditures for awareness and prevention activities, related to the earmarking requirement of Section 50. The Coalition could not provide supporting documentation for the percentage reported. While the percentage reported by the Coalition did not exceed the 30% earmarking threshold, we were unable to obtain sufficient appropriate evidence to support compliance with program earmarking. Cause: The Coalition did not maintain the supporting documentation for the percentage earmarking reported on semi-annual performance progress report due to change in personnel. Effect or potential effect: Without proper record retention, the Coalition is unable to support the amounts reported for earmarking percentages on their semi-annual performance progress report, causing potential noncompliance. Repeat Finding: Yes, 2020-003 Recommendation: We recommend that the Coalition develop policies and procedures for tracking actual expenditures related to earmarking requirements and maintain all supporting documentation for the calculation of the earmarking percentages that are reported in the semi-annual performance progress reports. Views of responsible officials: The Coalition's staff has developed policies and procedures for tracking actual expenditures related to these requirements, and maintaining all supporting documentation for the calculation of the earmarking percentages that are reported in the semi-annual progress reports. The Coalition has developed an internal control process for reviewing and approving calculations required by Section 50 of the grant agreement and has strengthened its reporting management review controls to ensure that the review is effective to ensure the completeness and accuracy of reports, and that all elements are appropriately supported, prior to submission the federal agency.
Finding 2021-006 – Lack of Internal Controls Over the Schedule of Expenditures of Federal Awards (SEFA) Condition: Total federal expenditures on the SEFA were understated by $375,034: • Expenditures reported on the SEFA for ALN 97.036 Disaster Grant – Public Assistance were $467,323. Actual federal expenditures obtained from the County’s records confirm $838,525 expended for an overstated variance of $371,202. • Expenditures reported on the SEFA for ALN 15.226 OMES/E911 GIS Tracking were $0. Actual federal expenditures obtained from the County’s records confirm $3,832 expended for an understated variance of $3,832. Cause of Condition: Policies and procedures have not been designed and implemented to ensure accurate reporting of expenditures on the SEFA. Effect of Condition: This condition resulted in erroneous reporting and a material misstatement of the County’s SEFA and could result in material noncompliance. Recommendation: OSAI recommends County Officials and department heads gain an understanding of federal programs awarded to Grant County. Internal control procedures should be designed and implemented to ensure accurate and timely reporting of expenditures on the SEFA and to ensure compliance with federal requirements. Management Response: County Commissioner District 1: We will discuss the SEFA completion in County Officers’ meeting. I will search for resources to aid in the completion of the SEFA. County Commissioner District 2: I will educate myself and do everything possible to become familiar with the requirements of the SEFA. County Commissioner District 3: We will address this issue as a County in the officers’ meetings. County Clerk: We have increased our understanding of the reporting requirement of the SEFA. 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. 2 CFR § 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR § 200.508(b) Auditee responsibilities reads as follows: The auditee must: Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. 2 CFR § 200.510(b) Financial statements reads, in part, as follows: Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. Further, GAO Standards – Section 2 – Objectives of an Entity – OV2.23 states in part: Compliance Objective 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 2021-007 – Lack of County-Wide Controls Over Major Federal Programs – Disaster Grants – Public Assistance (Presidentially Declared Disasters) 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 FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions QUESTIONED COSTS: $-0- Condition: Through the process of gaining an understanding of the County’s internal control structure for federal programs, it was noted that county-wide controls regarding Control Environment, Risk Assessment, Information and Communication, and Monitoring have not been designed. Cause of Condition: Policies and procedures have not been designed and implemented to ensure the County complies with federal grant requirements. Effect of Condition: Without an adequate system of county-wide controls, there is greater risk of a breakdown in control activities which could result in noncompliance to federal grant requirements. Recommendation: OSAI recommends that the County design and implement a system of county-wide procedures to identify and address risks related to compliance with federal award requirements and to ensure that information is communicated effectively. OSAI also recommends that the County design and implement monitoring procedures to assess the quality of performance over time. These procedures should be written policies and procedures and could be included in the County’s policies and procedures handbook. Management Response: County Commissioner District 1: We need to become more familiar with federal grant requirements and acknowledge that we understand the requirements to fulfill the grant. After which, we can establish the policies and procedures over federal expenditures. County Commissioner District 2: We are planning to meet as a group of officers to address county-wide internal controls and we will incorporate federal grants into these meetings. County Commissioner District 3: This issue will be addressed in the officers’ meetings. County Clerk: We have implemented new online software to assist with FEMA tracking requirements. We have developed open communication between the Emergency Manager, the Commissioners’ Executive Assistant, the County Treasurer, and the County Clerk to assist with implementation of controls. Criteria: 2 CFR § 200.303 - Internal Controls states in part: The non-Federal entity must: (a)Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Also, the GAO Standards – Section 1 – Fundamental Concepts of Internal Control – OV1.01 states in part: Definition of Internal Control Internal control is a process effected by an entity’s oversight body, management, and other personnel that provides reasonable assurance that the objectives of an entity will be achieved. Additionally, GAO Standards – Section 2 – Establishing an Effective Internal Control System – OV2.04 states in part: Components, Principles, and Attributes Control Environment – the foundation for an internal control system. It provides the discipline and structure to help an entity achieve its objectives. Risk Assessment – Assesses the risks facing the entity as it seeks to achieve its objectives. This assessment provides the basis for developing appropriate risk responses. Information and Communication – The quality information management and personnel communicate and use to support the internal control system. Monitoring – Activities management establishes and operates to assess the quality of performance over time and promptly resolve the findings of audits and other reviews.
Finding 2021-008 – Lack of Internal Controls Over Major Federal Programs – Disaster Grants – Public Assistance (Presidentially Declared Disasters) 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 FEDERAL AWARD YEAR: 2021 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 Grant County has not established procedures to ensure compliance with the following requirements: Activities Allowed or Unallowed; Allowable Costs/Costs 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 to federal compliance 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 design and implement internal control procedures to ensure compliance with federal grant requirements. Management Response: County Commissioner District 2: I will accept the recommendations and will acquire information to research federal grant compliance requirements to ensure adherence to the requirements. County Commissioner District 3: We need to educate ourselves as County Officials to better understand our duties over compliance requirements and research federal grant compliance requirements to ensure adherence to the requirements. County Clerk: We have hired a new Emergency Manager who has attended FEMA classes. We will invite her to share her information in a County Officers’ meeting. 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 2021-009 – Noncompliance with Compliance Requirements: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; and Special Tests and Provisions – Disaster Grants – Public Assistance (Presidentially Declared Disasters) 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 FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions QUESTIONED COSTS: $105,935 Condition: Upon inquiry of county personnel, review of documentation and procedures, and a test of five (5) out of seventeen (17) project worksheets, the following weaknesses were noted: Project Worksheet 365 (D3) Questioned Cost – $1,257: • Supporting documentation retained from projects were not reviewed or approved by anyone other than the preparer. • Project expense documentation was not adequately retained to verify costs of the equipment used and FEMA equipment rates were not consistently used by the district. Total unsupported county equipment costs $402. • Project expense documentation was not adequately retained to verify costs of the materials used. Total material costs reported exceeded documentation by $855. Project Worksheet 872 (D2) Questioned Cost – $15,152: • Supporting documentation retained from projects were not reviewed or approved by anyone other than the preparer. • Project expense documentation was not adequately retained to verify costs of the labor used and correct labor rates were not consistently used by the District. Total unsupported County labor costs $939. • Project expense documentation was not adequately retained to verify costs of the equipment used and FEMA equipment rates were not consistently used by the District. Total unsupported County equipment costs $9,946. • Project expense documentation was not adequately retained to verify costs of the materials used. Total material costs reported did not exceed the total County documentation. • Unallowed management costs were included in total project expenditures totaling $4,267. Project Worksheet 888 (D2) Questioned Cost – $19,885: • Supporting documentation retained from projects were not reviewed or approved by anyone other than the preparer. • Project expense documentation was not adequately retained to verify costs of the labor used and correct labor rates were not consistently used by the District. Total unsupported County labor costs $2,298. • Project expense documentation was not adequately retained to verify costs of the equipment used and FEMA equipment rates were not consistently used by the District. Total unsupported County equipment costs $10,551. • Project expense documentation was not adequately retained to verify costs of the materials used. Total material costs reported exceeded documentation by $640. • Unallowed management costs were included in total project expenditures totaling $6,396. Project Worksheet 967 (D2) Questioned Cost – $4,137: • Project expense documentation was not adequately retained to verify costs of the labor used and correct labor rates were not consistently used by the District. Total unsupported County labor costs $940. • Project expense documentation was not adequately retained to verify costs of the equipment used and FEMA equipment rates were not consistently used by the District. Total unsupported County equipment costs $2,408. • Project expense documentation was not adequately retained to verify costs of the materials used. Total material costs reported exceeded documentation by $180. • Unallowed management costs were included in total project expenditures totaling $609. Further, upon additional inquiry of staff and review of documentation over 100% of federal expenditures the following was noted: Project Worksheet 365 (D3): • One (1) Quarterly Report was not submitted within 30 days of the end of a calendar quarter. Project Worksheet 756 (D2) Questioned Cost – $41,417: • Project expenditures totaling $41,417 occurred after the period of performance deadline. Project Worksheet 986 (D3) Questioned Cost – $24,087: • Project expenditures totaling $24,087 occurred after the period of performance deadline. 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: These conditions resulted in noncompliance to federal 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. We further recommend all documentation be properly maintained for inspection. Management Response: County Commissioner District 2: I was not in office at this time, but I will discuss with my Administrative Assistant and determine the best way to track all project costs. County Commissioners District 3: I will have my Administrative Assistant double check her numbers and I also will review the documentation. 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 Non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part. [….] 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. [….]
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: During our testing, three out of the four vendors selected for testing did not have documentation to ensure the vendor was not suspended or debarred at the time the transaction was entered into. Additionally, we noted the College currently does not have a suspension and debarment policy or process in place. 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 2020-003. 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.
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: During our testing, three out of the four vendors selected for testing did not have documentation to ensure the vendor was not suspended or debarred at the time the transaction was entered into. Additionally, we noted the College currently does not have a suspension and debarment policy or process in place. 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 2020-003. 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.
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: During our testing, three out of the four vendors selected for testing did not have documentation to ensure the vendor was not suspended or debarred at the time the transaction was entered into. Additionally, we noted the College currently does not have a suspension and debarment policy or process in place. 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 2020-003. 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.
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: During our testing, three out of the four vendors selected for testing did not have documentation to ensure the vendor was not suspended or debarred at the time the transaction was entered into. Additionally, we noted the College currently does not have a suspension and debarment policy or process in place. 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 2020-003. 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.
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: During our testing, three out of the four vendors selected for testing did not have documentation to ensure the vendor was not suspended or debarred at the time the transaction was entered into. Additionally, we noted the College currently does not have a suspension and debarment policy or process in place. 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 2020-003. 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.
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: During our testing, three out of the four vendors selected for testing did not have documentation to ensure the vendor was not suspended or debarred at the time the transaction was entered into. Additionally, we noted the College currently does not have a suspension and debarment policy or process in place. 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 2020-003. 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.
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: During our testing, three out of the four vendors selected for testing did not have documentation to ensure the vendor was not suspended or debarred at the time the transaction was entered into. Additionally, we noted the College currently does not have a suspension and debarment policy or process in place. 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 2020-003. 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.
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: During our testing, three out of the four vendors selected for testing did not have documentation to ensure the vendor was not suspended or debarred at the time the transaction was entered into. Additionally, we noted the College currently does not have a suspension and debarment policy or process in place. 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 2020-003. 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.
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: During our testing, three out of the four vendors selected for testing did not have documentation to ensure the vendor was not suspended or debarred at the time the transaction was entered into. Additionally, we noted the College currently does not have a suspension and debarment policy or process in place. 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 2020-003. 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.
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: During our testing, three out of the four vendors selected for testing did not have documentation to ensure the vendor was not suspended or debarred at the time the transaction was entered into. Additionally, we noted the College currently does not have a suspension and debarment policy or process in place. 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 2020-003. 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.
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: During our testing, three out of the four vendors selected for testing did not have documentation to ensure the vendor was not suspended or debarred at the time the transaction was entered into. Additionally, we noted the College currently does not have a suspension and debarment policy or process in place. 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 2020-003. 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.
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: During our testing, three out of the four vendors selected for testing did not have documentation to ensure the vendor was not suspended or debarred at the time the transaction was entered into. Additionally, we noted the College currently does not have a suspension and debarment policy or process in place. 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 2020-003. 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.
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: During our testing, three out of the four vendors selected for testing did not have documentation to ensure the vendor was not suspended or debarred at the time the transaction was entered into. Additionally, we noted the College currently does not have a suspension and debarment policy or process in place. 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 2020-003. 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.
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)). Condition: The College did not have the percentage of federal participation in the project costs for the federal award under which the property was acquired in the property records. Questioned Costs: None. Context: During our testing of property and equipment purchases, it was noted that the modular building purchased with federal funds did not have the percentage of federal participation included in the property records. For the year ended June 30, 2021, costs for the purchase of the modular building were $227,056, all of which were from federal funds. Additionally, the property had not been tagged as having been purchased with federal funds. Cause: The College did not have the percentage of federal participation as part of their property and equipment records. Effect: The College did not meet equipment property record requirements for equipment purchased with federal funds. Repeat Finding: No 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. Views of responsible officials: Management agrees with the finding and has prepared a plan to correct the finding.
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)). Condition: The College did not have the percentage of federal participation in the project costs for the federal award under which the property was acquired in the property records. Questioned Costs: None. Context: During our testing of property and equipment purchases, it was noted that the modular building purchased with federal funds did not have the percentage of federal participation included in the property records. For the year ended June 30, 2021, costs for the purchase of the modular building were $227,056, all of which were from federal funds. Additionally, the property had not been tagged as having been purchased with federal funds. Cause: The College did not have the percentage of federal participation as part of their property and equipment records. Effect: The College did not meet equipment property record requirements for equipment purchased with federal funds. Repeat Finding: No 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. Views of responsible officials: Management agrees with the finding and has prepared a plan to correct the finding.
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 fourteen payroll disbursements selected for testing, it was noted that three employees were underpaid and five were overpaid based on the information available. Assistance Listing Number 47.076 and 93.859: • Of the forty payroll disbursements selected for testing, it was noted that one employee was underpaid and another disbursement where the same employee was overpaid. As a result, the amount charged to the grant was correct based on the amount the employee was ultimately paid, however the payments themselves were not correct. Assistance Listing Number 84.425K: • Of the twenty payroll disbursements selected for testing, it was noted that one employee was underpaid. Questioned Costs: Assistance Listing Number 15.027 - $4,007. Context: During our testing of payroll expenditures, the College was unable to provide support for payroll costs charged to the grants. Total payroll costs charged to assistance listing numbers 15.027, 47.076/93.859 and 84.425 were $4,337,717, $763,833 and $251,977, respectively. 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 eleven employees. Repeat Finding: No 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.
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 fourteen payroll disbursements selected for testing, it was noted that three employees were underpaid and five were overpaid based on the information available. Assistance Listing Number 47.076 and 93.859: • Of the forty payroll disbursements selected for testing, it was noted that one employee was underpaid and another disbursement where the same employee was overpaid. As a result, the amount charged to the grant was correct based on the amount the employee was ultimately paid, however the payments themselves were not correct. Assistance Listing Number 84.425K: • Of the twenty payroll disbursements selected for testing, it was noted that one employee was underpaid. Questioned Costs: Assistance Listing Number 15.027 - $4,007. Context: During our testing of payroll expenditures, the College was unable to provide support for payroll costs charged to the grants. Total payroll costs charged to assistance listing numbers 15.027, 47.076/93.859 and 84.425 were $4,337,717, $763,833 and $251,977, respectively. 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 eleven employees. Repeat Finding: No 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.
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 fourteen payroll disbursements selected for testing, it was noted that three employees were underpaid and five were overpaid based on the information available. Assistance Listing Number 47.076 and 93.859: • Of the forty payroll disbursements selected for testing, it was noted that one employee was underpaid and another disbursement where the same employee was overpaid. As a result, the amount charged to the grant was correct based on the amount the employee was ultimately paid, however the payments themselves were not correct. Assistance Listing Number 84.425K: • Of the twenty payroll disbursements selected for testing, it was noted that one employee was underpaid. Questioned Costs: Assistance Listing Number 15.027 - $4,007. Context: During our testing of payroll expenditures, the College was unable to provide support for payroll costs charged to the grants. Total payroll costs charged to assistance listing numbers 15.027, 47.076/93.859 and 84.425 were $4,337,717, $763,833 and $251,977, respectively. 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 eleven employees. Repeat Finding: No 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.
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 fourteen payroll disbursements selected for testing, it was noted that three employees were underpaid and five were overpaid based on the information available. Assistance Listing Number 47.076 and 93.859: • Of the forty payroll disbursements selected for testing, it was noted that one employee was underpaid and another disbursement where the same employee was overpaid. As a result, the amount charged to the grant was correct based on the amount the employee was ultimately paid, however the payments themselves were not correct. Assistance Listing Number 84.425K: • Of the twenty payroll disbursements selected for testing, it was noted that one employee was underpaid. Questioned Costs: Assistance Listing Number 15.027 - $4,007. Context: During our testing of payroll expenditures, the College was unable to provide support for payroll costs charged to the grants. Total payroll costs charged to assistance listing numbers 15.027, 47.076/93.859 and 84.425 were $4,337,717, $763,833 and $251,977, respectively. 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 eleven employees. Repeat Finding: No 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.
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 fourteen payroll disbursements selected for testing, it was noted that three employees were underpaid and five were overpaid based on the information available. Assistance Listing Number 47.076 and 93.859: • Of the forty payroll disbursements selected for testing, it was noted that one employee was underpaid and another disbursement where the same employee was overpaid. As a result, the amount charged to the grant was correct based on the amount the employee was ultimately paid, however the payments themselves were not correct. Assistance Listing Number 84.425K: • Of the twenty payroll disbursements selected for testing, it was noted that one employee was underpaid. Questioned Costs: Assistance Listing Number 15.027 - $4,007. Context: During our testing of payroll expenditures, the College was unable to provide support for payroll costs charged to the grants. Total payroll costs charged to assistance listing numbers 15.027, 47.076/93.859 and 84.425 were $4,337,717, $763,833 and $251,977, respectively. 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 eleven employees. Repeat Finding: No 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.
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 fourteen payroll disbursements selected for testing, it was noted that three employees were underpaid and five were overpaid based on the information available. Assistance Listing Number 47.076 and 93.859: • Of the forty payroll disbursements selected for testing, it was noted that one employee was underpaid and another disbursement where the same employee was overpaid. As a result, the amount charged to the grant was correct based on the amount the employee was ultimately paid, however the payments themselves were not correct. Assistance Listing Number 84.425K: • Of the twenty payroll disbursements selected for testing, it was noted that one employee was underpaid. Questioned Costs: Assistance Listing Number 15.027 - $4,007. Context: During our testing of payroll expenditures, the College was unable to provide support for payroll costs charged to the grants. Total payroll costs charged to assistance listing numbers 15.027, 47.076/93.859 and 84.425 were $4,337,717, $763,833 and $251,977, respectively. 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 eleven employees. Repeat Finding: No 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.
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 fourteen payroll disbursements selected for testing, it was noted that three employees were underpaid and five were overpaid based on the information available. Assistance Listing Number 47.076 and 93.859: • Of the forty payroll disbursements selected for testing, it was noted that one employee was underpaid and another disbursement where the same employee was overpaid. As a result, the amount charged to the grant was correct based on the amount the employee was ultimately paid, however the payments themselves were not correct. Assistance Listing Number 84.425K: • Of the twenty payroll disbursements selected for testing, it was noted that one employee was underpaid. Questioned Costs: Assistance Listing Number 15.027 - $4,007. Context: During our testing of payroll expenditures, the College was unable to provide support for payroll costs charged to the grants. Total payroll costs charged to assistance listing numbers 15.027, 47.076/93.859 and 84.425 were $4,337,717, $763,833 and $251,977, respectively. 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 eleven employees. Repeat Finding: No 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.
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 fourteen payroll disbursements selected for testing, it was noted that three employees were underpaid and five were overpaid based on the information available. Assistance Listing Number 47.076 and 93.859: • Of the forty payroll disbursements selected for testing, it was noted that one employee was underpaid and another disbursement where the same employee was overpaid. As a result, the amount charged to the grant was correct based on the amount the employee was ultimately paid, however the payments themselves were not correct. Assistance Listing Number 84.425K: • Of the twenty payroll disbursements selected for testing, it was noted that one employee was underpaid. Questioned Costs: Assistance Listing Number 15.027 - $4,007. Context: During our testing of payroll expenditures, the College was unable to provide support for payroll costs charged to the grants. Total payroll costs charged to assistance listing numbers 15.027, 47.076/93.859 and 84.425 were $4,337,717, $763,833 and $251,977, respectively. 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 eleven employees. Repeat Finding: No 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.
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 fourteen payroll disbursements selected for testing, it was noted that three employees were underpaid and five were overpaid based on the information available. Assistance Listing Number 47.076 and 93.859: • Of the forty payroll disbursements selected for testing, it was noted that one employee was underpaid and another disbursement where the same employee was overpaid. As a result, the amount charged to the grant was correct based on the amount the employee was ultimately paid, however the payments themselves were not correct. Assistance Listing Number 84.425K: • Of the twenty payroll disbursements selected for testing, it was noted that one employee was underpaid. Questioned Costs: Assistance Listing Number 15.027 - $4,007. Context: During our testing of payroll expenditures, the College was unable to provide support for payroll costs charged to the grants. Total payroll costs charged to assistance listing numbers 15.027, 47.076/93.859 and 84.425 were $4,337,717, $763,833 and $251,977, respectively. 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 eleven employees. Repeat Finding: No 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.