2024-008 8540.17 Department Of Education Student Financial Aid 84.063, 84.268 "P063P218567-2024 P268K228567-2024" N/A N/A 7/1/23 - 6/30/24 Significant Deficiency Did not result in material questioned costs therefore will document as a SD. Finding is neither systemic nor will it lead to 5% questioned cost. N/A "The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Six Title IV checks were observed during testing that were stale more than 240 days. 4333.85 The University had six stale Title IV checks greater than 240 days The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Funds are not returned to the Department of Education in a timely manner No We recommend that the University review policies and procedures related to student refund checks to ensure stale checks are returned to the Department of Education. Management agrees with this finding. See 0100.25
2024-008 8540.17 Department Of Education Student Financial Aid 84.063, 84.268 "P063P218567-2024 P268K228567-2024" N/A N/A 7/1/23 - 6/30/24 Significant Deficiency Did not result in material questioned costs therefore will document as a SD. Finding is neither systemic nor will it lead to 5% questioned cost. N/A "The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Six Title IV checks were observed during testing that were stale more than 240 days. 4333.85 The University had six stale Title IV checks greater than 240 days The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Funds are not returned to the Department of Education in a timely manner No We recommend that the University review policies and procedures related to student refund checks to ensure stale checks are returned to the Department of Education. Management agrees with this finding. See 0100.25
2024-009 8565.02 Department Of Education Student Financial Aid 84.063, 84.268 "P063P218567-2024 P268K228567-2024" N/A N/A 7/1/23 - 6/30/24 Significant Deficiency Did not result in material questioned costs therefore will document as a SD. Finding is neither systemic nor will it lead to 5% questioned cost. N/A "The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by an institution participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. An institution must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed. Per 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." The University did not have documentation that Direct Loan Reconciliation prepared by third-party servicer was reviewed. N/A During our testing we examined four months of direct loan reconciliations (August, December, March, & May). For all four, the University's third party servicer (Campus Ivy) performed preparation and review of the reconciliation; however, Urshan did not review the work of Campus Ivy or a SOC1 report. The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements. No We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Management agrees with this finding. See 0100.25
2024-009 8565.02 Department Of Education Student Financial Aid 84.063, 84.268 "P063P218567-2024 P268K228567-2024" N/A N/A 7/1/23 - 6/30/24 Significant Deficiency Did not result in material questioned costs therefore will document as a SD. Finding is neither systemic nor will it lead to 5% questioned cost. N/A "The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by an institution participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. An institution must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed. Per 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." The University did not have documentation that Direct Loan Reconciliation prepared by third-party servicer was reviewed. N/A During our testing we examined four months of direct loan reconciliations (August, December, March, & May). For all four, the University's third party servicer (Campus Ivy) performed preparation and review of the reconciliation; however, Urshan did not review the work of Campus Ivy or a SOC1 report. The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements. No We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Management agrees with this finding. See 0100.25
2024-010 8540.15 Department Of Education Student Financial Aid 84.063, 84.268 "P063P218567-2024 P268K228567-2024" N/A N/A 7/1/23 - 6/30/24 Significant Deficiency Control finding did not result in material questioned costs-therefore we will document as a SD. N/A - I/C Finding Only Finding is neither systemic nor will it lead to 5% questioned cost. N/A Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The University used a third-party servicer to perform key controls, but did not have documented review of the work performed by their third-party servicer. Additionally, we were unable to observe evidence that the University reviewed cash drawdowns prepared by the third party processor. N/A During our testing of Credit Balance refunds, CLA observed that the University did not have documentation of formal review. Additionally, during our testing of Cash Management CLA observed two draws that we were unable to verify review occurred. The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements. No We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Management agrees with this finding. See 0100.25
2024-010 8540.15 Department Of Education Student Financial Aid 84.063, 84.268 "P063P218567-2024 P268K228567-2024" N/A N/A 7/1/23 - 6/30/24 Significant Deficiency Control finding did not result in material questioned costs-therefore we will document as a SD. N/A - I/C Finding Only Finding is neither systemic nor will it lead to 5% questioned cost. N/A Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The University used a third-party servicer to perform key controls, but did not have documented review of the work performed by their third-party servicer. Additionally, we were unable to observe evidence that the University reviewed cash drawdowns prepared by the third party processor. N/A During our testing of Credit Balance refunds, CLA observed that the University did not have documentation of formal review. Additionally, during our testing of Cash Management CLA observed two draws that we were unable to verify review occurred. The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements. No We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Management agrees with this finding. See 0100.25
Program Information: Home Investment Partnerships Program (ALN #14.239) and Coronavirus State and Local Fiscal Recovery Funds (ALN #21.027) Criteria: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332, the subaward is to clearly identify to the subrecipient required information, including identification that the award is a subaward by providing information described in 200.332 (b)(1); all requirements imposed by the Pass-through Entity (PTE) on the subrecipient so that the federal award is used in accordance with federal statutes, regulations; and the terms and conditions of the award; and any additional requirements that the PTE imposes on the subrecipient. Additionally, per 2 CFR section 200.332 (f), the Organization should verify that a subrecipient is audited as required. Condition: The subawards did not include the required federal provisions or list the assistance listing numbers. The Organization did not obtain the most recently available audit reports of subrecipients. Questioned Costs: None. Context: This condition occurred for 8 out of 8 subawards selected for testing. Cause: Insufficient internal control and administrative oversight. Effect or Potential Effect: The subrecipients may not be aware of certain award information in order to comply with federal statutes, regulations, and the terms and conditions of the award. Repeat Finding: No
Program Information: Home Investment Partnerships Program (ALN #14.239) and Coronavirus State and Local Fiscal Recovery Funds (ALN #21.027) Criteria: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332, the subaward is to clearly identify to the subrecipient required information, including identification that the award is a subaward by providing information described in 200.332 (b)(1); all requirements imposed by the Pass-through Entity (PTE) on the subrecipient so that the federal award is used in accordance with federal statutes, regulations; and the terms and conditions of the award; and any additional requirements that the PTE imposes on the subrecipient. Additionally, per 2 CFR section 200.332 (f), the Organization should verify that a subrecipient is audited as required. Condition: The subawards did not include the required federal provisions or list the assistance listing numbers. The Organization did not obtain the most recently available audit reports of subrecipients. Questioned Costs: None. Context: This condition occurred for 8 out of 8 subawards selected for testing. Cause: Insufficient internal control and administrative oversight. Effect or Potential Effect: The subrecipients may not be aware of certain award information in order to comply with federal statutes, regulations, and the terms and conditions of the award. Repeat Finding: No
Program Information: Home Investment Partnerships Program (ALN #14.239) and Coronavirus State and Local Fiscal Recovery Funds (ALN #21.027) Criteria: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332, the subaward is to clearly identify to the subrecipient required information, including identification that the award is a subaward by providing information described in 200.332 (b)(1); all requirements imposed by the Pass-through Entity (PTE) on the subrecipient so that the federal award is used in accordance with federal statutes, regulations; and the terms and conditions of the award; and any additional requirements that the PTE imposes on the subrecipient. Additionally, per 2 CFR section 200.332 (f), the Organization should verify that a subrecipient is audited as required. Condition: The subawards did not include the required federal provisions or list the assistance listing numbers. The Organization did not obtain the most recently available audit reports of subrecipients. Questioned Costs: None. Context: This condition occurred for 8 out of 8 subawards selected for testing. Cause: Insufficient internal control and administrative oversight. Effect or Potential Effect: The subrecipients may not be aware of certain award information in order to comply with federal statutes, regulations, and the terms and conditions of the award. Repeat Finding: No
Program Information: Home Investment Partnerships Program (ALN #14.239) and Coronavirus State and Local Fiscal Recovery Funds (ALN #21.027) Criteria: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332, the subaward is to clearly identify to the subrecipient required information, including identification that the award is a subaward by providing information described in 200.332 (b)(1); all requirements imposed by the Pass-through Entity (PTE) on the subrecipient so that the federal award is used in accordance with federal statutes, regulations; and the terms and conditions of the award; and any additional requirements that the PTE imposes on the subrecipient. Additionally, per 2 CFR section 200.332 (f), the Organization should verify that a subrecipient is audited as required. Condition: The subawards did not include the required federal provisions or list the assistance listing numbers. The Organization did not obtain the most recently available audit reports of subrecipients. Questioned Costs: None. Context: This condition occurred for 8 out of 8 subawards selected for testing. Cause: Insufficient internal control and administrative oversight. Effect or Potential Effect: The subrecipients may not be aware of certain award information in order to comply with federal statutes, regulations, and the terms and conditions of the award. Repeat Finding: No
2022-004 Impact Aid Application Controls (Repeated 2023-004) CFDA Title: Impact Aid CFDA Number: 84.041 Federal Award Number: Federal Agency: Department of Education Pass-through Entity: Condition: The District does not have an internal control system in place to ensure that supporting documentation is maintained to support the Impact Aid Applications for the elementary and high school. This is a repeat finding from the prior year audit. Criteria: 1. 2 CFR section 200.303 requires that the District establish and maintain an effective internal control system over the federal award to provide reasonable assurance that the District is managing the federal awards in compliance with federal statutes, regulations and the terms and conditions of the federal award. 2. Application for Impact Aid - Section 7003 (OMB No. 1810-0687) - Each year an LEA must submit this application, which provides the following information: counts of federally connected children in various categories, membership and average daily attendance data, and information on expenditures for children with disabilities. This form is in the Impact Aid Grant System, which does not have a public link, therefore school districts will need to provide a copy to the auditor. Context: We requested the supporting documentation to test the compliance of reported students counts on the elementary and high school impact aid applications, but the District had a difficult time providing the supporting application and trust land documentation to support the application. The verification of the trust land students from the Tribe had to be provided again from the trip to support spreadsheets of the students and their addresses. Effect: The District risk of noncompliance with federal programs increases if documentation is not maintained to support those compliance requirements. Cause: The District did not establish and maintain an adequate internal control system ensure that supporting documentation is maintained to support the membership counts of the children who live on Indian lands. Recommendation: We recommend that the District review its internal control systems over its Impact Aid application, and ensure that the document management systems are adequate to ensure appropriate filing of supporting documentation to the applications are maintained so that information can be found in future years.
2024-001 ACTIVITIES ALLOWED OR UNALLOWED (REPEAT OF PRIOR YEAR FINDING 2023-0001) Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.403(g) states that costs must “Be adequately documented.” Condition: During our testing of activities allowed or unallowed, for 4 of the 60 nonpayroll items tested, management could not provide adequate support that the charges were properly reviewed and approved prior to payment. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board did not demonstrate that proper internal controls are in place and operating effectively to ensure that unallowable charges to the federal program do not occur. Effect: Unallowable payments to the federal program may have occurred due to the lack of effective internal controls in place. Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-001 ACTIVITIES ALLOWED OR UNALLOWED (REPEAT OF PRIOR YEAR FINDING 2023-0001) Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.403(g) states that costs must “Be adequately documented.” Condition: During our testing of activities allowed or unallowed, for 4 of the 60 nonpayroll items tested, management could not provide adequate support that the charges were properly reviewed and approved prior to payment. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board did not demonstrate that proper internal controls are in place and operating effectively to ensure that unallowable charges to the federal program do not occur. Effect: Unallowable payments to the federal program may have occurred due to the lack of effective internal controls in place. Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-001 ACTIVITIES ALLOWED OR UNALLOWED (REPEAT OF PRIOR YEAR FINDING 2023-0001) Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.403(g) states that costs must “Be adequately documented.” Condition: During our testing of activities allowed or unallowed, for 4 of the 60 nonpayroll items tested, management could not provide adequate support that the charges were properly reviewed and approved prior to payment. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board did not demonstrate that proper internal controls are in place and operating effectively to ensure that unallowable charges to the federal program do not occur. Effect: Unallowable payments to the federal program may have occurred due to the lack of effective internal controls in place. Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-001 ACTIVITIES ALLOWED OR UNALLOWED (REPEAT OF PRIOR YEAR FINDING 2023-0001) Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.403(g) states that costs must “Be adequately documented.” Condition: During our testing of activities allowed or unallowed, for 4 of the 60 nonpayroll items tested, management could not provide adequate support that the charges were properly reviewed and approved prior to payment. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board did not demonstrate that proper internal controls are in place and operating effectively to ensure that unallowable charges to the federal program do not occur. Effect: Unallowable payments to the federal program may have occurred due to the lack of effective internal controls in place. Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-001 ACTIVITIES ALLOWED OR UNALLOWED (REPEAT OF PRIOR YEAR FINDING 2023-0001) Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.403(g) states that costs must “Be adequately documented.” Condition: During our testing of activities allowed or unallowed, for 4 of the 60 nonpayroll items tested, management could not provide adequate support that the charges were properly reviewed and approved prior to payment. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board did not demonstrate that proper internal controls are in place and operating effectively to ensure that unallowable charges to the federal program do not occur. Effect: Unallowable payments to the federal program may have occurred due to the lack of effective internal controls in place. Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-001 ACTIVITIES ALLOWED OR UNALLOWED (REPEAT OF PRIOR YEAR FINDING 2023-0001) Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.403(g) states that costs must “Be adequately documented.” Condition: During our testing of activities allowed or unallowed, for 4 of the 60 nonpayroll items tested, management could not provide adequate support that the charges were properly reviewed and approved prior to payment. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board did not demonstrate that proper internal controls are in place and operating effectively to ensure that unallowable charges to the federal program do not occur. Effect: Unallowable payments to the federal program may have occurred due to the lack of effective internal controls in place. Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-001 ACTIVITIES ALLOWED OR UNALLOWED (REPEAT OF PRIOR YEAR FINDING 2023-0001) Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.403(g) states that costs must “Be adequately documented.” Condition: During our testing of activities allowed or unallowed, for 4 of the 60 nonpayroll items tested, management could not provide adequate support that the charges were properly reviewed and approved prior to payment. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board did not demonstrate that proper internal controls are in place and operating effectively to ensure that unallowable charges to the federal program do not occur. Effect: Unallowable payments to the federal program may have occurred due to the lack of effective internal controls in place. Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-002 REPORTING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Board is required to submit MACC reports to WorkForce WV on a monthly basis. Condition: During our testing of reporting, for all MACC reports selected for testing management could not provide adequate support that the MACC reports were properly reviewed and approved prior to being submitted. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board did not have adequate policies and internal controls in place to ensure that all required reports for the WIOA Cluster were reviewed and approved prior to submission. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-002 REPORTING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Board is required to submit MACC reports to WorkForce WV on a monthly basis. Condition: During our testing of reporting, for all MACC reports selected for testing management could not provide adequate support that the MACC reports were properly reviewed and approved prior to being submitted. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board did not have adequate policies and internal controls in place to ensure that all required reports for the WIOA Cluster were reviewed and approved prior to submission. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-002 REPORTING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Board is required to submit MACC reports to WorkForce WV on a monthly basis. Condition: During our testing of reporting, for all MACC reports selected for testing management could not provide adequate support that the MACC reports were properly reviewed and approved prior to being submitted. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board did not have adequate policies and internal controls in place to ensure that all required reports for the WIOA Cluster were reviewed and approved prior to submission. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-002 REPORTING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Board is required to submit MACC reports to WorkForce WV on a monthly basis. Condition: During our testing of reporting, for all MACC reports selected for testing management could not provide adequate support that the MACC reports were properly reviewed and approved prior to being submitted. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board did not have adequate policies and internal controls in place to ensure that all required reports for the WIOA Cluster were reviewed and approved prior to submission. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-002 REPORTING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Board is required to submit MACC reports to WorkForce WV on a monthly basis. Condition: During our testing of reporting, for all MACC reports selected for testing management could not provide adequate support that the MACC reports were properly reviewed and approved prior to being submitted. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board did not have adequate policies and internal controls in place to ensure that all required reports for the WIOA Cluster were reviewed and approved prior to submission. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-002 REPORTING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Board is required to submit MACC reports to WorkForce WV on a monthly basis. Condition: During our testing of reporting, for all MACC reports selected for testing management could not provide adequate support that the MACC reports were properly reviewed and approved prior to being submitted. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board did not have adequate policies and internal controls in place to ensure that all required reports for the WIOA Cluster were reviewed and approved prior to submission. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-002 REPORTING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Board is required to submit MACC reports to WorkForce WV on a monthly basis. Condition: During our testing of reporting, for all MACC reports selected for testing management could not provide adequate support that the MACC reports were properly reviewed and approved prior to being submitted. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board did not have adequate policies and internal controls in place to ensure that all required reports for the WIOA Cluster were reviewed and approved prior to submission. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-003 SUBRECIPIENT MONITORING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Recipients must ensure that commercial organizations that are subrecipients under WIOA Title I and expend more than the minimum level specified in 2 CFR Part 200, Subpart F, have either an organization-wide audit conducted in accordance with 2 CFR Part 200 or a program-specific financial and compliance audit (20 CFR section 683.210). 2 CFR 200.332(b) requires that all pass-through entities must: Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section. Condition: The Board did not maintain documentation of monitoring procedures performed on its subrecipient during the fiscal year ended June 30, 2024. The Board obtained the subrecipient’s audit report; however documentation of review of the audit report and risk assessment procedures performed on the subrecipient were not maintained as evidence of subrecipient monitoring performed. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024, which included $293,830 of expenditures to subrecipients. Cause: The Board adopted policies and procedures surrounding the subrecipient monitoring compliance requirements in February 2025; however, no documented evidence of subrecipient monitoring completed during the fiscal year ended June 30, 2024 could be provided. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement its recently adopted policies and procedures and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-003 SUBRECIPIENT MONITORING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Recipients must ensure that commercial organizations that are subrecipients under WIOA Title I and expend more than the minimum level specified in 2 CFR Part 200, Subpart F, have either an organization-wide audit conducted in accordance with 2 CFR Part 200 or a program-specific financial and compliance audit (20 CFR section 683.210). 2 CFR 200.332(b) requires that all pass-through entities must: Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section. Condition: The Board did not maintain documentation of monitoring procedures performed on its subrecipient during the fiscal year ended June 30, 2024. The Board obtained the subrecipient’s audit report; however documentation of review of the audit report and risk assessment procedures performed on the subrecipient were not maintained as evidence of subrecipient monitoring performed. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024, which included $293,830 of expenditures to subrecipients. Cause: The Board adopted policies and procedures surrounding the subrecipient monitoring compliance requirements in February 2025; however, no documented evidence of subrecipient monitoring completed during the fiscal year ended June 30, 2024 could be provided. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement its recently adopted policies and procedures and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-003 SUBRECIPIENT MONITORING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Recipients must ensure that commercial organizations that are subrecipients under WIOA Title I and expend more than the minimum level specified in 2 CFR Part 200, Subpart F, have either an organization-wide audit conducted in accordance with 2 CFR Part 200 or a program-specific financial and compliance audit (20 CFR section 683.210). 2 CFR 200.332(b) requires that all pass-through entities must: Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section. Condition: The Board did not maintain documentation of monitoring procedures performed on its subrecipient during the fiscal year ended June 30, 2024. The Board obtained the subrecipient’s audit report; however documentation of review of the audit report and risk assessment procedures performed on the subrecipient were not maintained as evidence of subrecipient monitoring performed. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024, which included $293,830 of expenditures to subrecipients. Cause: The Board adopted policies and procedures surrounding the subrecipient monitoring compliance requirements in February 2025; however, no documented evidence of subrecipient monitoring completed during the fiscal year ended June 30, 2024 could be provided. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement its recently adopted policies and procedures and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-003 SUBRECIPIENT MONITORING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Recipients must ensure that commercial organizations that are subrecipients under WIOA Title I and expend more than the minimum level specified in 2 CFR Part 200, Subpart F, have either an organization-wide audit conducted in accordance with 2 CFR Part 200 or a program-specific financial and compliance audit (20 CFR section 683.210). 2 CFR 200.332(b) requires that all pass-through entities must: Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section. Condition: The Board did not maintain documentation of monitoring procedures performed on its subrecipient during the fiscal year ended June 30, 2024. The Board obtained the subrecipient’s audit report; however documentation of review of the audit report and risk assessment procedures performed on the subrecipient were not maintained as evidence of subrecipient monitoring performed. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024, which included $293,830 of expenditures to subrecipients. Cause: The Board adopted policies and procedures surrounding the subrecipient monitoring compliance requirements in February 2025; however, no documented evidence of subrecipient monitoring completed during the fiscal year ended June 30, 2024 could be provided. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement its recently adopted policies and procedures and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-003 SUBRECIPIENT MONITORING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Recipients must ensure that commercial organizations that are subrecipients under WIOA Title I and expend more than the minimum level specified in 2 CFR Part 200, Subpart F, have either an organization-wide audit conducted in accordance with 2 CFR Part 200 or a program-specific financial and compliance audit (20 CFR section 683.210). 2 CFR 200.332(b) requires that all pass-through entities must: Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section. Condition: The Board did not maintain documentation of monitoring procedures performed on its subrecipient during the fiscal year ended June 30, 2024. The Board obtained the subrecipient’s audit report; however documentation of review of the audit report and risk assessment procedures performed on the subrecipient were not maintained as evidence of subrecipient monitoring performed. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024, which included $293,830 of expenditures to subrecipients. Cause: The Board adopted policies and procedures surrounding the subrecipient monitoring compliance requirements in February 2025; however, no documented evidence of subrecipient monitoring completed during the fiscal year ended June 30, 2024 could be provided. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement its recently adopted policies and procedures and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-003 SUBRECIPIENT MONITORING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Recipients must ensure that commercial organizations that are subrecipients under WIOA Title I and expend more than the minimum level specified in 2 CFR Part 200, Subpart F, have either an organization-wide audit conducted in accordance with 2 CFR Part 200 or a program-specific financial and compliance audit (20 CFR section 683.210). 2 CFR 200.332(b) requires that all pass-through entities must: Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section. Condition: The Board did not maintain documentation of monitoring procedures performed on its subrecipient during the fiscal year ended June 30, 2024. The Board obtained the subrecipient’s audit report; however documentation of review of the audit report and risk assessment procedures performed on the subrecipient were not maintained as evidence of subrecipient monitoring performed. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024, which included $293,830 of expenditures to subrecipients. Cause: The Board adopted policies and procedures surrounding the subrecipient monitoring compliance requirements in February 2025; however, no documented evidence of subrecipient monitoring completed during the fiscal year ended June 30, 2024 could be provided. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement its recently adopted policies and procedures and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-003 SUBRECIPIENT MONITORING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Recipients must ensure that commercial organizations that are subrecipients under WIOA Title I and expend more than the minimum level specified in 2 CFR Part 200, Subpart F, have either an organization-wide audit conducted in accordance with 2 CFR Part 200 or a program-specific financial and compliance audit (20 CFR section 683.210). 2 CFR 200.332(b) requires that all pass-through entities must: Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section. Condition: The Board did not maintain documentation of monitoring procedures performed on its subrecipient during the fiscal year ended June 30, 2024. The Board obtained the subrecipient’s audit report; however documentation of review of the audit report and risk assessment procedures performed on the subrecipient were not maintained as evidence of subrecipient monitoring performed. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024, which included $293,830 of expenditures to subrecipients. Cause: The Board adopted policies and procedures surrounding the subrecipient monitoring compliance requirements in February 2025; however, no documented evidence of subrecipient monitoring completed during the fiscal year ended June 30, 2024 could be provided. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement its recently adopted policies and procedures and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-004 ELIGIBILITY Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per the provisions of the Workforce Innovation and Opportunity Act (WIOA), “A person is eligible to receive services under Youth Activities if they are an out-of-school youth or an in-school youth (Section 129(a)(1), WIOA, 128 Stat. 1504)”, and meet the definition of such as defined in the Uniform Guidance. To be eligible to receive career services as an adult in the adult and dislocated worker programs, an individual must be 18 years of age or older. To be eligible for any dislocated worker programs, an eligible adult must meet the criteria of 20 CFR 680.130. Eligibility criteria for training services are found at 20 CFR 680.210. Condition: During our testing of WIOA participants, it was noted that for two of the nine youth participants selected for testing the WIOA intake application was not signed by the participant/guardian and/or the case manager. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board’s policies and procedures are not sufficient to ensure that all participant applications are complete and approved for eligibility prior to disbursement of federal funds. Effect: Youth Activities participant(s) may be granted access to the Board’s program when they do not meet the prescribed eligibility requirements. Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth Activities participants. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-004 ELIGIBILITY Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per the provisions of the Workforce Innovation and Opportunity Act (WIOA), “A person is eligible to receive services under Youth Activities if they are an out-of-school youth or an in-school youth (Section 129(a)(1), WIOA, 128 Stat. 1504)”, and meet the definition of such as defined in the Uniform Guidance. To be eligible to receive career services as an adult in the adult and dislocated worker programs, an individual must be 18 years of age or older. To be eligible for any dislocated worker programs, an eligible adult must meet the criteria of 20 CFR 680.130. Eligibility criteria for training services are found at 20 CFR 680.210. Condition: During our testing of WIOA participants, it was noted that for two of the nine youth participants selected for testing the WIOA intake application was not signed by the participant/guardian and/or the case manager. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board’s policies and procedures are not sufficient to ensure that all participant applications are complete and approved for eligibility prior to disbursement of federal funds. Effect: Youth Activities participant(s) may be granted access to the Board’s program when they do not meet the prescribed eligibility requirements. Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth Activities participants. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-004 ELIGIBILITY Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per the provisions of the Workforce Innovation and Opportunity Act (WIOA), “A person is eligible to receive services under Youth Activities if they are an out-of-school youth or an in-school youth (Section 129(a)(1), WIOA, 128 Stat. 1504)”, and meet the definition of such as defined in the Uniform Guidance. To be eligible to receive career services as an adult in the adult and dislocated worker programs, an individual must be 18 years of age or older. To be eligible for any dislocated worker programs, an eligible adult must meet the criteria of 20 CFR 680.130. Eligibility criteria for training services are found at 20 CFR 680.210. Condition: During our testing of WIOA participants, it was noted that for two of the nine youth participants selected for testing the WIOA intake application was not signed by the participant/guardian and/or the case manager. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board’s policies and procedures are not sufficient to ensure that all participant applications are complete and approved for eligibility prior to disbursement of federal funds. Effect: Youth Activities participant(s) may be granted access to the Board’s program when they do not meet the prescribed eligibility requirements. Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth Activities participants. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-004 ELIGIBILITY Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per the provisions of the Workforce Innovation and Opportunity Act (WIOA), “A person is eligible to receive services under Youth Activities if they are an out-of-school youth or an in-school youth (Section 129(a)(1), WIOA, 128 Stat. 1504)”, and meet the definition of such as defined in the Uniform Guidance. To be eligible to receive career services as an adult in the adult and dislocated worker programs, an individual must be 18 years of age or older. To be eligible for any dislocated worker programs, an eligible adult must meet the criteria of 20 CFR 680.130. Eligibility criteria for training services are found at 20 CFR 680.210. Condition: During our testing of WIOA participants, it was noted that for two of the nine youth participants selected for testing the WIOA intake application was not signed by the participant/guardian and/or the case manager. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board’s policies and procedures are not sufficient to ensure that all participant applications are complete and approved for eligibility prior to disbursement of federal funds. Effect: Youth Activities participant(s) may be granted access to the Board’s program when they do not meet the prescribed eligibility requirements. Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth Activities participants. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-004 ELIGIBILITY Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per the provisions of the Workforce Innovation and Opportunity Act (WIOA), “A person is eligible to receive services under Youth Activities if they are an out-of-school youth or an in-school youth (Section 129(a)(1), WIOA, 128 Stat. 1504)”, and meet the definition of such as defined in the Uniform Guidance. To be eligible to receive career services as an adult in the adult and dislocated worker programs, an individual must be 18 years of age or older. To be eligible for any dislocated worker programs, an eligible adult must meet the criteria of 20 CFR 680.130. Eligibility criteria for training services are found at 20 CFR 680.210. Condition: During our testing of WIOA participants, it was noted that for two of the nine youth participants selected for testing the WIOA intake application was not signed by the participant/guardian and/or the case manager. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board’s policies and procedures are not sufficient to ensure that all participant applications are complete and approved for eligibility prior to disbursement of federal funds. Effect: Youth Activities participant(s) may be granted access to the Board’s program when they do not meet the prescribed eligibility requirements. Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth Activities participants. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-004 ELIGIBILITY Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per the provisions of the Workforce Innovation and Opportunity Act (WIOA), “A person is eligible to receive services under Youth Activities if they are an out-of-school youth or an in-school youth (Section 129(a)(1), WIOA, 128 Stat. 1504)”, and meet the definition of such as defined in the Uniform Guidance. To be eligible to receive career services as an adult in the adult and dislocated worker programs, an individual must be 18 years of age or older. To be eligible for any dislocated worker programs, an eligible adult must meet the criteria of 20 CFR 680.130. Eligibility criteria for training services are found at 20 CFR 680.210. Condition: During our testing of WIOA participants, it was noted that for two of the nine youth participants selected for testing the WIOA intake application was not signed by the participant/guardian and/or the case manager. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board’s policies and procedures are not sufficient to ensure that all participant applications are complete and approved for eligibility prior to disbursement of federal funds. Effect: Youth Activities participant(s) may be granted access to the Board’s program when they do not meet the prescribed eligibility requirements. Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth Activities participants. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-004 ELIGIBILITY Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per the provisions of the Workforce Innovation and Opportunity Act (WIOA), “A person is eligible to receive services under Youth Activities if they are an out-of-school youth or an in-school youth (Section 129(a)(1), WIOA, 128 Stat. 1504)”, and meet the definition of such as defined in the Uniform Guidance. To be eligible to receive career services as an adult in the adult and dislocated worker programs, an individual must be 18 years of age or older. To be eligible for any dislocated worker programs, an eligible adult must meet the criteria of 20 CFR 680.130. Eligibility criteria for training services are found at 20 CFR 680.210. Condition: During our testing of WIOA participants, it was noted that for two of the nine youth participants selected for testing the WIOA intake application was not signed by the participant/guardian and/or the case manager. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024. Cause: The Board’s policies and procedures are not sufficient to ensure that all participant applications are complete and approved for eligibility prior to disbursement of federal funds. Effect: Youth Activities participant(s) may be granted access to the Board’s program when they do not meet the prescribed eligibility requirements. Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth Activities participants. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
Federal Agency: Department of Health and Human Services Federal Program Name: HeadStart Assistance Listing Number: 93.600 Federal Award Identification Number and Year: 03CH011220-04-00, 2023 03CH011220-05-00, 2024 Award Period: 9/1/2022-8/31/2023 9/1/2023-8/31/2024 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria or Specific Requirement: Compliance: Per 2 CFR 200 § 200.332(a)1 (d) a non-Federal entity should monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Community and Human Services (DCHS) did not provide documentation to support monitoring of the subrecipient’s activities. Questioned Costs: None Context: DCHS has one sub awardee and issued a subaward in the amount of $2,822,089. Cause: DCHS’ procedures did not maintain supporting documentation of subrecipient monitoring activities. Effect: DCHS was unable to provide evidence they were in compliance with subrecipient monitoring requirements. Repeat Finding: No Recommendation: We recommend that DCHS enhance procedures to ensure that sub recipient monitoring activities are documented, and evidence of compliance readily available for review. Views of Responsible Officials: There is no disagreement with the audit finding and new personnel in the Department of Community and Human Services will ensure that all required monitoring is performed and documented in a timely manner.
Federal Agency: Department of Health and Human Services Federal Program Name: HeadStart Assistance Listing Number: 93.600 Federal Award Identification Number and Year: 03CH011220-04-00, 2023 03CH011220-05-00, 2024 Award Period: 9/1/2022-8/31/2023 9/1/2023-8/31/2024 Compliance Requirement: Reporting: Federal Funding Accountability and Transparency Act Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria or Specific Requirement: Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $25,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Community and Human Services (DCHS) did not report subaward information to the FFATA Subaward Reporting System (FSRS) in accordance with Federal Funding Accountability and Transparency Act (FFATA) requirements. As the prime award recipient DCHS is responsible for ensuring that all reporting requirements are met within the required timeframe. Context: The sole fiscal year 2024 subaward issued by DCHS was not reported to FSRS. In addition, the Department was unable to produce documentation supporting their review and approval of the tested FFATA reports prior to submission in the FSRS system. Transactions Subaward Report not Subaward Subaward Tested not reported timely amount missing key incorrect elements 1 1 0 0 0 Dollar Amount Subaward Report not Subaward Subaward of Tested not reported timely amount missing key Transactions incorrect elements $2,822,089 $2,822,089 0 $0 $0 Cause: DCHS’ procedures and internal controls were not sufficient to ensure that the subaward reporting requirement was performed within the requirement time frame. Effect: DCHS is not in compliance with the FFATA reporting requirement. Questioned costs: None. Recommendation: We recommend that DCHS review procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation of supporting compliance should be readily available for review. Views of Responsible Officials: There is no disagreement with this finding. The reporting has been completed. New employees will be trained in the procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation will be available for review during the audit period.
Federal Agency: Department of Health and Human Services Federal Program Name: Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A, 2024 Award Period: 7/1/2023-6/30/2024 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities: a) Checking SAM Exclusions; or b) Collecting a certification from that person; or c) Adding a clause or condition to the covered transaction with that person. Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The City was unable to provide documentation of a vendor’s suspension and debarment status. The City is required to review and document a vendor’s suspension and debarment status prior to contracting with the vendor. We noted that the City did not document the vendor’s status in accordance with the federal requirements. Questioned Costs: None Context: Two of the two vendors selected for the fiscal year 2024 testing did not have evidence of the vendor’s suspension and debarment status prior to the contract date. Cause: The contractors selected for testing were not updated to include the suspension and debarment clause. Effect: The City is unable to document compliance with suspension and debarment status prior to contracting with the vendor. Repeat Finding: No Recommendation: We recommend that the City review and enhance current procedures to ensure that the vendor’s suspension and debarment status is documented prior to contracting with the vendor. Views of Responsible Officials: There is no disagreement with the audit finding and new personnel in the Department of Community and Human Services will ensure that all required monitoring is performed and documented in a timely manner.
Federal Agency: Department of Health and Human Services Federal Program Name: Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A, 2024 Award Period: 7/1/2023-6/30/2024 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities: a) Checking SAM Exclusions; or b) Collecting a certification from that person; or c) Adding a clause or condition to the covered transaction with that person. Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The City was unable to provide documentation of a vendor’s suspension and debarment status. The City is required to review and document a vendor’s suspension and debarment status prior to contracting with the vendor. We noted that the City did not document the vendor’s status in accordance with the federal requirements. Questioned Costs: None Context: Two of the two vendors selected for the fiscal year 2024 testing did not have evidence of the vendor’s suspension and debarment status prior to the contract date. Cause: The contractors selected for testing were not updated to include the suspension and debarment clause. Effect: The City is unable to document compliance with suspension and debarment status prior to contracting with the vendor. Repeat Finding: No Recommendation: We recommend that the City review and enhance current procedures to ensure that the vendor’s suspension and debarment status is documented prior to contracting with the vendor. Views of Responsible Officials: There is no disagreement with the audit finding and new personnel in the Department of Community and Human Services will ensure that all required monitoring is performed and documented in a timely manner.
Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. 2 CFR Part 176 Subpart C requires nonfederal entities to include provisions requiring compliance with the Wage-Rate requirements in federally-funded construction contracts exceeding $2,000, and to collect certified payrolls from contractors and subcontractors for every week in which contract work is performed. Condition: There were no controls over the wage rate compliance requirements which resulted in the District being unaware that two of the contractors did not have the required Davis-Bacon wage rate clause in their contracts and were not submitting the required certified payrolls. Cause: While the District was aware that wage-rate requirements applied to construction type federal grant expenditures, they did not consider whether these requirements were considered in projects originally intended to be paid from non-federal funds. The funding source of certain projects was changed mid process and the District did not have a process in place to review the agreements for compliance with federal grant requirements prior to the change. Effect: The District’s lack of controls over the wage rate compliance requirements led to deficiencies within the compliance requirements resulting in questioned costs of $773,629. Perspective: Errors noted in actual dollar amounts are not material to the grant. The noncompliance was considered at 100% of the amounts paid under the two contracts that did not include the Wage Rate requirements and for which no certified payrolls were obtained. There were two other contractors under which $2,802,969 was paid that were in compliance with the wage rate requirements. Therefore, there are no amounts of unknown questioned costs. In addition, the questioned costs noted stem from control deficiencies rather than intentional noncompliance as management was unaware that contractors were required to have both the Davis-Bacon wage rate clause in their contracts and to submit certified payrolls. Questioned Costs: Questioned costs were considered at 100%. Total questioned costs were $773,629. Recommendation: The District should implement and document standardized processes and procedures to identify that contractors have the required Davis-Bacon wage rate clause in their contracts and to ensure that contractors are submitting certified payrolls. We also recommend general training be completed for all staff regarding this requirement to standardize the process throughout the District and consider when other processes may be more effective and efficient if not specifically required. Management Response: See attached Corrective Action Plan.
Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. 2 CFR Part 176 Subpart C requires nonfederal entities to include provisions requiring compliance with the Wage-Rate requirements in federally-funded construction contracts exceeding $2,000, and to collect certified payrolls from contractors and subcontractors for every week in which contract work is performed. Condition: There were no controls over the wage rate compliance requirements which resulted in the District being unaware that two of the contractors did not have the required Davis-Bacon wage rate clause in their contracts and were not submitting the required certified payrolls. Cause: While the District was aware that wage-rate requirements applied to construction type federal grant expenditures, they did not consider whether these requirements were considered in projects originally intended to be paid from non-federal funds. The funding source of certain projects was changed mid process and the District did not have a process in place to review the agreements for compliance with federal grant requirements prior to the change. Effect: The District’s lack of controls over the wage rate compliance requirements led to deficiencies within the compliance requirements resulting in questioned costs of $773,629. Perspective: Errors noted in actual dollar amounts are not material to the grant. The noncompliance was considered at 100% of the amounts paid under the two contracts that did not include the Wage Rate requirements and for which no certified payrolls were obtained. There were two other contractors under which $2,802,969 was paid that were in compliance with the wage rate requirements. Therefore, there are no amounts of unknown questioned costs. In addition, the questioned costs noted stem from control deficiencies rather than intentional noncompliance as management was unaware that contractors were required to have both the Davis-Bacon wage rate clause in their contracts and to submit certified payrolls. Questioned Costs: Questioned costs were considered at 100%. Total questioned costs were $773,629. Recommendation: The District should implement and document standardized processes and procedures to identify that contractors have the required Davis-Bacon wage rate clause in their contracts and to ensure that contractors are submitting certified payrolls. We also recommend general training be completed for all staff regarding this requirement to standardize the process throughout the District and consider when other processes may be more effective and efficient if not specifically required. Management Response: See attached Corrective Action Plan.
Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. 2 CFR Part 176 Subpart C requires nonfederal entities to include provisions requiring compliance with the Wage-Rate requirements in federally-funded construction contracts exceeding $2,000, and to collect certified payrolls from contractors and subcontractors for every week in which contract work is performed. Condition: There were no controls over the wage rate compliance requirements which resulted in the District being unaware that two of the contractors did not have the required Davis-Bacon wage rate clause in their contracts and were not submitting the required certified payrolls. Cause: While the District was aware that wage-rate requirements applied to construction type federal grant expenditures, they did not consider whether these requirements were considered in projects originally intended to be paid from non-federal funds. The funding source of certain projects was changed mid process and the District did not have a process in place to review the agreements for compliance with federal grant requirements prior to the change. Effect: The District’s lack of controls over the wage rate compliance requirements led to deficiencies within the compliance requirements resulting in questioned costs of $773,629. Perspective: Errors noted in actual dollar amounts are not material to the grant. The noncompliance was considered at 100% of the amounts paid under the two contracts that did not include the Wage Rate requirements and for which no certified payrolls were obtained. There were two other contractors under which $2,802,969 was paid that were in compliance with the wage rate requirements. Therefore, there are no amounts of unknown questioned costs. In addition, the questioned costs noted stem from control deficiencies rather than intentional noncompliance as management was unaware that contractors were required to have both the Davis-Bacon wage rate clause in their contracts and to submit certified payrolls. Questioned Costs: Questioned costs were considered at 100%. Total questioned costs were $773,629. Recommendation: The District should implement and document standardized processes and procedures to identify that contractors have the required Davis-Bacon wage rate clause in their contracts and to ensure that contractors are submitting certified payrolls. We also recommend general training be completed for all staff regarding this requirement to standardize the process throughout the District and consider when other processes may be more effective and efficient if not specifically required. Management Response: See attached Corrective Action Plan.
Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. 2 CFR Part 176 Subpart C requires nonfederal entities to include provisions requiring compliance with the Wage-Rate requirements in federally-funded construction contracts exceeding $2,000, and to collect certified payrolls from contractors and subcontractors for every week in which contract work is performed. Condition: There were no controls over the wage rate compliance requirements which resulted in the District being unaware that two of the contractors did not have the required Davis-Bacon wage rate clause in their contracts and were not submitting the required certified payrolls. Cause: While the District was aware that wage-rate requirements applied to construction type federal grant expenditures, they did not consider whether these requirements were considered in projects originally intended to be paid from non-federal funds. The funding source of certain projects was changed mid process and the District did not have a process in place to review the agreements for compliance with federal grant requirements prior to the change. Effect: The District’s lack of controls over the wage rate compliance requirements led to deficiencies within the compliance requirements resulting in questioned costs of $773,629. Perspective: Errors noted in actual dollar amounts are not material to the grant. The noncompliance was considered at 100% of the amounts paid under the two contracts that did not include the Wage Rate requirements and for which no certified payrolls were obtained. There were two other contractors under which $2,802,969 was paid that were in compliance with the wage rate requirements. Therefore, there are no amounts of unknown questioned costs. In addition, the questioned costs noted stem from control deficiencies rather than intentional noncompliance as management was unaware that contractors were required to have both the Davis-Bacon wage rate clause in their contracts and to submit certified payrolls. Questioned Costs: Questioned costs were considered at 100%. Total questioned costs were $773,629. Recommendation: The District should implement and document standardized processes and procedures to identify that contractors have the required Davis-Bacon wage rate clause in their contracts and to ensure that contractors are submitting certified payrolls. We also recommend general training be completed for all staff regarding this requirement to standardize the process throughout the District and consider when other processes may be more effective and efficient if not specifically required. Management Response: See attached Corrective Action Plan.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, the Subrecipient Agreement, with the County of Santa Barbara, notes NBCC “shall obtain written approval from COUNTY for the use of any funds provided under this Agreement for the reimbursement of any costs incurred for travel outside the County of Santa Barbara.” Condition Two of the 25 expenditures selected for testing, associated with the above award, were related to travel outside of the County of Santa Barbara. We subsequently reviewed the detail of expenditures charged to this award, noting multiple other transactions. Additionally, we noted the client did not have prior approval to allocate funds to this award. Cause NBCC’s internal controls are not properly designed and enforced to be in line with Federal guidelines, or take into account specific requirements of Federal awards. Repeat Finding No. Effect NBCC’s lack of internal controls may allow improper expenditures to be charged to Federal awards. This may impact future funding from Federal awards. Recommendation We recommend NBCC establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that NBCC is managing the Awards in compliance with Federal statues and regulations, as well as the terms and conditions set forth in the specific Federal Award or subrecipient agreement.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Condition During the course of our eligibility testing, we noted one of the 45 selections where the individual was not part of the program during the fiscal year-under audit. The individual had been incorrectly included in the population, and in various reports for this program. Cause NBCC’s internal controls are not properly designed and enforced to be in line with Federal guidelines, or take into account specific requirements of Federal awards. Repeat Finding No. Effect NBCC’s lack of internal controls may allow for individuals to receive benefits who are not eligibility to participate in Federally funded programs. Additionally, these discrepancies may lead to incorrect Federal reporting. This may impact future funding from Federal awards. Recommendation We recommend NBCC establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that NBCC is managing the Awards in compliance with Federal statues and regulations, as well as the terms and conditions set forth in the specific Federal Award or subrecipient agreement.
AL No: 20.507 Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster - Direct Award Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles. Condition: The District’s internal controls over compliance requirements did not identify ineligible costs applied to two separate Federal Transit Administration (FTA) grants as follows. Section 5307 Grant Award CA-2020-173-01: The District overclaimed Sacramento fixed route operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in ineligible costs of $183,848 being charged to the program. Questioned Costs: $183,548 Section 5307 Grant Award CA-2023-122-01: The District overclaimed Woodland fixed route operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in ineligible costs of $175,143 being charged to the program. Questioned Costs: $175,143. In addition to these ineligible costs, there were substantial changes to the Schedule of Expenditures of Federal Awards (SEFA) and federal grant revenue reported in the general ledger (GL) during the course of the audit. These changes and issues are as follows. There was a total of $302,813 removed from the SEFA and GL for claims prepared for expenses incurred after the period of performance end date specified in the grant for the relevant project and therefore would have been ineligible if the claim was submitted to the grantor. These claims were prepared for paratransit and microtransit operating assistance. There was a total of $243,823 removed from the SEFA and GL for claims prepared for an FTA direct program grant that is already past the end date of the period of performance and therefore would have been ineligible if the claim was submitted to the grantor. These claims were drafted for Woodland microtransit operating assistance. There was a total of $354,429 added to the SEFA for federal grant revenues recorded in the GL but not initially included on the SEFA. These claims are for the Yolo County Bike and Pedestrian Trail Network Planning Project and the Yolo 80 Managed Lanes Tolling Advance Planning project. There was a total of $1,106,389 of expenses reported on the SEFA but not recognized as revenue in the GL for amounts previously overclaimed for ineligible expenses but reclaimed and approved for eligible expenses in the current period. Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal 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.” Cause:. Grant management procedures are not documented and a schedule of all available grants was not prepared by the District to use when reconciling expenses for inclusion on the SEFA and accruing grant revenue. The errors on the SEFA were not captured by the District’s review procedures due to recent staff turnover, lack of documented procedures on grant management, and/or lack of training. Effect: Expenses were omitted from the SEFA that should have been included and other expenses were included on the SEFA that were not eligible. The SEFA had to be revised for multiple grants over the course of the audit, which delayed the audit testing and major program determination process. Context: The number of grants has increased since the pandemic due to new pandemic related grants becoming available that delayed the use of the District’s regular federal grants. This caused grants to be combined by grantors with different allowable expenses, areas of service, and periods of performance and caused grants to be extended, causing complexity. The District confirmed that there will be no other federal grants used for reimbursement of the expenses that were removed from the SEFA during the audit. Recommendation: We recommend the District develop written procedures to allocate expenses to routes and purposes under federal grants that document the timing of the preparation and review of the allocation schedule. A summary tab should be added to the allocation schedule to reconcile amounts for each route/purpose to total operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the population of expenses in the general ledger. We also recommend the District develop a schedule to summarize all approved and pending grants that includes the amounts available under each grant, each route/purpose within each grant, periods of performance for each amount available, the last date to submit invoices, and amounts claimed and still available for each grant by route/purpose. The District should re-evaluate budgets if changes or delays occur to federal grants and ensure a new federal or local funding source is identified and claimed for the expenses. The SEFA should be prepared after expenses are reconciled to the GL at the invoice level by route/purpose and the allocation schedule is thoroughly reviewed. The SEFA should be reviewed by a knowledgeable member of management to ensure completeness and accuracy. We also recommend the District claim expenses more quickly to allow the granting agency time to review and approve the claims before the audit begins. We recommend the District reconcile expenses within 30 days of quarter end and prepare claims within 45 days of quarter end. If the District is unsure about the period of performance dates or other restrictions on a grant, staff should contact the granting agency for clarification. Finally, we recommend the District discuss the overclaimed amounts of $183,548 and $175,143 described above with the FTA to determine whether these overclaimed funds must be returned or whether they may be used to claim future expenses. View of Responsible Officials and Planned Corrective Action: Management’s response and planned corrective action is included at the Corrective Action Plan end of this report.