2024 – 003 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2402LLIEA 6/1/2024; 2302ILLIEI 3/1/2023; G 2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038 Award Period: June 1, 2024 through September 30, 2025; March 1, 2023 through August 31, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.308, 200.309, and 200.403(h)) requires that only allowable costs incurred during the approved budget period of a federal award’s period of performance be charged to the award. Effective internal controls should include procedures that involve costs charged to federal awards being reviewed and approved for proper period of performance. Condition: The County charged costs to the federal award after the end of the period of performance. Furthermore, although payroll transactions charged to the federal award were reviewed and approved, documentation of such review was not retained. Questioned Costs: $706 Context: 4 of 97 transactions tested were incurred after the period of performance end date. All 18 payroll transactions tested lacked documentation of review and approval. Cause: Costs were inadvertently claimed outside the period of performance. Documentation of review and approval for payroll transactions was also not retained. Effect: Charging costs outside the period of performance can result in unallowable costs being charged to federal awards, which could lead to noncompliance with federal requirements and potential repayment obligations. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-005. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 003 Period of Performance (Continued) Recommendation: We recommend that the County review and strengthen its internal controls to ensure that only costs incurred within the period of performance are charged. Costs charged to federal awards should be reviewed and approved for proper period of performance, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 003 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2402LLIEA 6/1/2024; 2302ILLIEI 3/1/2023; G 2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038 Award Period: June 1, 2024 through September 30, 2025; March 1, 2023 through August 31, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.308, 200.309, and 200.403(h)) requires that only allowable costs incurred during the approved budget period of a federal award’s period of performance be charged to the award. Effective internal controls should include procedures that involve costs charged to federal awards being reviewed and approved for proper period of performance. Condition: The County charged costs to the federal award after the end of the period of performance. Furthermore, although payroll transactions charged to the federal award were reviewed and approved, documentation of such review was not retained. Questioned Costs: $706 Context: 4 of 97 transactions tested were incurred after the period of performance end date. All 18 payroll transactions tested lacked documentation of review and approval. Cause: Costs were inadvertently claimed outside the period of performance. Documentation of review and approval for payroll transactions was also not retained. Effect: Charging costs outside the period of performance can result in unallowable costs being charged to federal awards, which could lead to noncompliance with federal requirements and potential repayment obligations. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-005. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 003 Period of Performance (Continued) Recommendation: We recommend that the County review and strengthen its internal controls to ensure that only costs incurred within the period of performance are charged. Costs charged to federal awards should be reviewed and approved for proper period of performance, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 003 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2402LLIEA 6/1/2024; 2302ILLIEI 3/1/2023; G 2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038 Award Period: June 1, 2024 through September 30, 2025; March 1, 2023 through August 31, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.308, 200.309, and 200.403(h)) requires that only allowable costs incurred during the approved budget period of a federal award’s period of performance be charged to the award. Effective internal controls should include procedures that involve costs charged to federal awards being reviewed and approved for proper period of performance. Condition: The County charged costs to the federal award after the end of the period of performance. Furthermore, although payroll transactions charged to the federal award were reviewed and approved, documentation of such review was not retained. Questioned Costs: $706 Context: 4 of 97 transactions tested were incurred after the period of performance end date. All 18 payroll transactions tested lacked documentation of review and approval. Cause: Costs were inadvertently claimed outside the period of performance. Documentation of review and approval for payroll transactions was also not retained. Effect: Charging costs outside the period of performance can result in unallowable costs being charged to federal awards, which could lead to noncompliance with federal requirements and potential repayment obligations. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-005. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 003 Period of Performance (Continued) Recommendation: We recommend that the County review and strengthen its internal controls to ensure that only costs incurred within the period of performance are charged. Costs charged to federal awards should be reviewed and approved for proper period of performance, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024-001 - SEFA REPORTING Federal Program Information: Federal Agency and Program Name - National Endowment for the Humanities Promotion of the Humanities Federal/State Partnership Grant Number: SO-289836-23 Federal Assistance Listing Number 45.129 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 200.510(b) states that “the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502.” Condition: The Council’s internal controls are not adequate to ensure the Schedule of Expenditures of Federal Awards (SEFA) accurately reports Federal assistance. The Council’s fiscal year 2024 SEFA for the Promotion of the Humanities Federal/State Partnership program included expenditures from other fiscal years. Questioned Costs: Not applicable. Context: Total federal expenditures for the Promotion of the Humanities Federal/State Partnership program were $902,649 for the year ended October 31, 2024. Cause: The Council does not have adequate internal controls in place to ensure the accuracy of the SEFA. Effect: The Council is not reporting accurate financial information in its SEFA. Identification as a Repeat Finding: Prior Year Finding 2023-004 Recommendation: We recommend that the Council implement controls over financial reporting, including the SEFA, to ensure accuracy of financial data. Views of Responsible Officials: Management acknowledges the finding. See corrective action plan.
2024-001 - SEFA REPORTING Federal Program Information: Federal Agency and Program Name - National Endowment for the Humanities Promotion of the Humanities Federal/State Partnership Grant Number: SO-289836-23 Federal Assistance Listing Number 45.129 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 200.510(b) states that “the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502.” Condition: The Council’s internal controls are not adequate to ensure the Schedule of Expenditures of Federal Awards (SEFA) accurately reports Federal assistance. The Council’s fiscal year 2024 SEFA for the Promotion of the Humanities Federal/State Partnership program included expenditures from other fiscal years. Questioned Costs: Not applicable. Context: Total federal expenditures for the Promotion of the Humanities Federal/State Partnership program were $902,649 for the year ended October 31, 2024. Cause: The Council does not have adequate internal controls in place to ensure the accuracy of the SEFA. Effect: The Council is not reporting accurate financial information in its SEFA. Identification as a Repeat Finding: Prior Year Finding 2023-004 Recommendation: We recommend that the Council implement controls over financial reporting, including the SEFA, to ensure accuracy of financial data. Views of Responsible Officials: Management acknowledges the finding. See corrective action plan.
Department of Health and Human Services Temporary Assistance for Needy Families, 93.558, Affects awards FAST X for the year ending 12/31/2024 and Benefits Cliff for the year ending 12/31/2024 under assistance listing 93.558 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Goodwill-Easter Seals Minnesota’s internal control structure should be designed to properly follow the allocation policy for employees’ pay to each grant in accordance with the policy established by Goodwill-Easter Seals Minnesota. Condition: Goodwill-Easter Seals Minnesota has an internal control system designed to detect or prevent improper allocation of employees pay to grants in a timely manner in accordance with their established policy, however, during the year for two pay periods tested, it did not identify errors in the process. Cause: Goodwill-Easter Seals Minnesota has a process for allocating employee wages based on hours worked. The controls in place did not operate as designed and failed to detect errors in the allocation of employee pay to the grants. Effect: Employees had some of their pay allocated improperly and not in accordance with the policy established. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of seven pay periods out of 26 were selected for testing which accounted for $1,458,797 of $2,490,122 of federal program expenditures. Repeat Finding from Prior Year: No Recommendation: We recommend that management develop a more extensive review over payroll allocation to ensure pay is properly allocated to each grant in accordance with the policy established by Goodwill-Easter Seals Minnesota. Views of Responsible Officials: Management agrees with this finding.
Department of Health and Human Services Temporary Assistance for Needy Families, 93.558, Affects awards FAST X for the year ending 12/31/2024 and Benefits Cliff for the year ending 12/31/2024 under assistance listing 93.558 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Goodwill-Easter Seals Minnesota’s internal control structure should be designed to properly follow the allocation policy for employees’ pay to each grant in accordance with the policy established by Goodwill-Easter Seals Minnesota. Condition: Goodwill-Easter Seals Minnesota has an internal control system designed to detect or prevent improper allocation of employees pay to grants in a timely manner in accordance with their established policy, however, during the year for two pay periods tested, it did not identify errors in the process. Cause: Goodwill-Easter Seals Minnesota has a process for allocating employee wages based on hours worked. The controls in place did not operate as designed and failed to detect errors in the allocation of employee pay to the grants. Effect: Employees had some of their pay allocated improperly and not in accordance with the policy established. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of seven pay periods out of 26 were selected for testing which accounted for $1,458,797 of $2,490,122 of federal program expenditures. Repeat Finding from Prior Year: No Recommendation: We recommend that management develop a more extensive review over payroll allocation to ensure pay is properly allocated to each grant in accordance with the policy established by Goodwill-Easter Seals Minnesota. Views of Responsible Officials: Management agrees with this finding.
Department of Health and Human Services Temporary Assistance for Needy Families, 93.558, Affects awards FAST X for the year ending 12/31/2024 and Benefits Cliff for the year ending 12/31/2024 under assistance listing 93.558 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Goodwill-Easter Seals Minnesota’s internal control structure should be designed to properly follow the allocation policy for employees’ pay to each grant in accordance with the policy established by Goodwill-Easter Seals Minnesota. Condition: Goodwill-Easter Seals Minnesota has an internal control system designed to detect or prevent improper allocation of employees pay to grants in a timely manner in accordance with their established policy, however, during the year for two pay periods tested, it did not identify errors in the process. Cause: Goodwill-Easter Seals Minnesota has a process for allocating employee wages based on hours worked. The controls in place did not operate as designed and failed to detect errors in the allocation of employee pay to the grants. Effect: Employees had some of their pay allocated improperly and not in accordance with the policy established. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of seven pay periods out of 26 were selected for testing which accounted for $1,458,797 of $2,490,122 of federal program expenditures. Repeat Finding from Prior Year: No Recommendation: We recommend that management develop a more extensive review over payroll allocation to ensure pay is properly allocated to each grant in accordance with the policy established by Goodwill-Easter Seals Minnesota. Views of Responsible Officials: Management agrees with this finding.
Department of Health and Human Services Temporary Assistance for Needy Families, 93.558, Affects awards FAST X for the year ending 12/31/2024 and Benefits Cliff for the year ending 12/31/2024 under assistance listing 93.558 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Goodwill-Easter Seals Minnesota’s internal control structure should be designed to properly follow the allocation policy for employees’ pay to each grant in accordance with the policy established by Goodwill-Easter Seals Minnesota. Condition: Goodwill-Easter Seals Minnesota has an internal control system designed to detect or prevent improper allocation of employees pay to grants in a timely manner in accordance with their established policy, however, during the year for two pay periods tested, it did not identify errors in the process. Cause: Goodwill-Easter Seals Minnesota has a process for allocating employee wages based on hours worked. The controls in place did not operate as designed and failed to detect errors in the allocation of employee pay to the grants. Effect: Employees had some of their pay allocated improperly and not in accordance with the policy established. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of seven pay periods out of 26 were selected for testing which accounted for $1,458,797 of $2,490,122 of federal program expenditures. Repeat Finding from Prior Year: No Recommendation: We recommend that management develop a more extensive review over payroll allocation to ensure pay is properly allocated to each grant in accordance with the policy established by Goodwill-Easter Seals Minnesota. Views of Responsible Officials: Management agrees with this finding.
Informaon on the Federal Program: Assistance Lisng Number 10.565—Commodity Supplemental Food Program, U.S. Department of Agriculture Pass‐Through Enes and Award Numbers: Minnesota Department of Health, award number 204642. Compliance Requirement: Eligibility Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR 200.303 of Subpart D, "Post Federal Award Requirements Standards for Financial and Program Management," of the Uniform Guidance requires a nonfederal enty to establish and maintain effecve internal control over the federal award that provides reasonable assurance that the enty is managing the federal award in compliance with federal statutes, regulaons, and the terms and condions of the federal award, including Eligibility. Condion: We requested eligibility forms for forty‐four parcipants to review for the signature of site partner personnel indicang review of eligibility informaon on the form. Three of the forty‐four forms were unable to be located upon request. Eligibility informaon is input in ClientTrack soware and the form should also be uploaded. Cause: Signed enrollment forms were not properly scanned into Sharepoint and had likely been disposed of. The signatures on these forms indicated the review of an agency partner indicang the informaon included on the form is correct. Effect or Potenal Effect: An ineligible individual could receive a CSFP box. Quesoned Costs: None Context: Signed enrollment forms were not available for three of forty‐four parcipants selected. Repeat Finding: yes, 2023‐002 Recommendaon: We recommend that Second Harvest Heartland digitalize their CSFP enrollment forms for convenient access and provide review of the electronically filed form prior to disposal of the paper form. Views of Responsible Officials: Agree.
Finding 2024-001 – Material weakness over amounts reported on the Schedule of Expenditures of Federal Awards (SEFA) Identification of the federal program: Federal Granting Agency: U.S. Department of Homeland Security, Federal Emergency Management Agency (FEMA) Award Name: COVID-19 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Pass-through entity: Vermont Department of Public Safety and New York State Division of Homeland Security and Emergency Services Criteria or specific requirement: 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The preliminary fiscal year 2024 expenditures reported on the schedule of expenditures of federal awards (SEFA) for the COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) program (Disaster Grants program) incorrectly excluded Disaster Grants program funding that was obligated by FEMA during fiscal year 2024. Cause: Management did not have effective internal controls in place to ensure accurate reporting of the obligated funds for the Disaster Grants program. Effect or potential effect: Certain obligated amounts were incorrectly reported in the preliminary SEFA for the year ended September 30, 2024. Questioned costs: None. The updated SEFA, as presented in this report, was adjusted for the item noted in the Context section below. Context: Certain obligated amounts were incorrectly reported in the preliminary SEFA for the year ended September 30, 2024. After commencement of the Uniform Guidance audit procedures, adjustments of $18,199,589 were made to correctly report the SEFA amounts related to the Disaster Grants program. Identification as a repeat finding, if applicable: No. Recommendation: Management should reassess its internal controls over the review and approval process of the SEFA preparation. Views of responsible officials: Management has updated internal controls for the review and approval of the SEFA. Outlier projects (unique grant projects that aren’t recorded in the grant recording system) are reviewed for Uniform Guidance reporting based on program-specific guidance. Once complete, another member of management reviews the SEFA and general ledger details for accuracy. When questions arise, discussion will occur to ensure accuracy in the amounts reported on the SEFA.
Finding 2024-001 – Material weakness over amounts reported on the Schedule of Expenditures of Federal Awards (SEFA) Identification of the federal program: Federal Granting Agency: U.S. Department of Homeland Security, Federal Emergency Management Agency (FEMA) Award Name: COVID-19 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Pass-through entity: Vermont Department of Public Safety and New York State Division of Homeland Security and Emergency Services Criteria or specific requirement: 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The preliminary fiscal year 2024 expenditures reported on the schedule of expenditures of federal awards (SEFA) for the COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) program (Disaster Grants program) incorrectly excluded Disaster Grants program funding that was obligated by FEMA during fiscal year 2024. Cause: Management did not have effective internal controls in place to ensure accurate reporting of the obligated funds for the Disaster Grants program. Effect or potential effect: Certain obligated amounts were incorrectly reported in the preliminary SEFA for the year ended September 30, 2024. Questioned costs: None. The updated SEFA, as presented in this report, was adjusted for the item noted in the Context section below. Context: Certain obligated amounts were incorrectly reported in the preliminary SEFA for the year ended September 30, 2024. After commencement of the Uniform Guidance audit procedures, adjustments of $18,199,589 were made to correctly report the SEFA amounts related to the Disaster Grants program. Identification as a repeat finding, if applicable: No. Recommendation: Management should reassess its internal controls over the review and approval process of the SEFA preparation. Views of responsible officials: Management has updated internal controls for the review and approval of the SEFA. Outlier projects (unique grant projects that aren’t recorded in the grant recording system) are reviewed for Uniform Guidance reporting based on program-specific guidance. Once complete, another member of management reviews the SEFA and general ledger details for accuracy. When questions arise, discussion will occur to ensure accuracy in the amounts reported on the SEFA.
Criteria: According to 2 CFR 200.303, a non-federal entity must maintain effective internal control that provides reasonable assurance that the non-federal entity complies with Federal statutes, regulations, and the conditions of the Federal award. In the context of payroll expenditures, internal control should ensure that costs charged to the Federal program are allowable, in particular that they are allocable to the program (i.e. based on actual hours worked). Condition: For employees charging less than 100% of their payroll to the federal program, timesheets were used to identify time spent on program and nonprogram activities. During our testing of these payroll transactions, we noted 9 instances where the portion of an employee’s pay reimbursed by the program was different than the portion of hours supported by the timesheet. Cause: The District’s process for calculating these split payroll costs, and subsequently requesting reimbursement, did not include detailed review of all supporting calculations. Thus, the accuracy of certain requested payroll amounts relied on the personnel creating the reimbursement request. Effect or Potential Effect: While the noted errors did not result in charging unallowable costs, undetected future errors could cause funds to be drawn for payroll beyond the amount related to the program. Recommendation: We recommend that the District strengthen its controls over reimbursement requests by increasing the scope and detail of review prior to submission to the granting agency. Secondary review should be performed by another individual who did not prepare the original request when practicable.Contact Person Responsible For Corrective Action: Greg Ballentine, Executive Director Anticipated Completion Date: September 30, 2025 Management’s Response: Management acknowledges receipt of the audit report concerning our internal controls related to the review of reimbursement request worksheets. We appreciate the insight provided in identifying areas for improvement. While multiple levels of internal review were conducted during the creation of the base worksheet, we recognize the addition of columns could inadvertently introduce minor calculation errors and minor, inadvertent employee input errors could occur. To address this, we have implemented a procedure requiring that all worksheets undergo a review by an individual who did not prepare the original reimbursement request.
2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.
2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.
2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.
2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.
2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.
2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.
2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.
2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.
2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.
2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.
2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.
2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.
2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.
2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.
2024-001 – Internal Control over Compliance and Compliance with Reporting Information on the Major Federal Program: Federal Agency: Department of Interior Program Name: National Park Service Second Century Endowment and Appropriation Assistance Listing Number: 15.U01 Award Number: H.R. 4680/P.L. 114-289 Award Period: October 1, 2023 to September 30, 2024 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of the Federal Funding and Accountability Act (FFATA), which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, the Foundation is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. Condition – During our testing of reporting, we selected fourteen subrecipient awards. For all samples tested, the Foundation did not comply with the mandatory FFATA report filing requirements. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 14 14 14 Not applicable – no report was submitted Not applicable – no report was submitted Dollar Amount of Tested 2024 Subawards Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 4,984,134 $ 4,984,134 $ 4,984,134 Not applicable – no report was submitted Not applicable – no report was submitted Cause - The Foundation did not have adequate policies and procedures in place to ensure compliance with the FFATA filing requirements. Effect or Potential Effect - Failure to comply with the reporting requirements of the Uniform Guidance could result in noncompliance and awarding agency taking administrative action. Questioned Costs – None. Context - This is a condition identified based upon our review of the Foundation’s compliance with specified requirements. The sample was selected based on a non-statistical basis. The prevalence of these finding is detailed in the condition section above. Repeat Finding – This is a repeat finding from prior year. This was reported as finding 2023-003 in the 2023 report. Recommendation – BDO noted management’s actions to address prior year finding, however, the Foundation’s grant agreement do not have a Federal Award Identification Number (FAIN) which is a requirement to file FFATA, management is still unable to file the required FFATA reporting. BDO recommends that the Foundation continue to work with federal grantor/agencies to determine the required information and immediately file the required requirements. Views of Responsible Officials – The Foundation’s management has been given a legal opinion from counsel that the Appropriation and the Endowment are exempt from Uniform Guidance and the Single Audit. As such, will continue to work with Department of Interior to remedy this situation. The planned corrective actions are presented in the Foundation’s management’s corrective action plan attached as Appendix C.
2024-001 – Internal Control over Compliance and Compliance with Reporting Information on the Major Federal Program: Federal Agency: Department of Interior Program Name: National Park Service Second Century Endowment and Appropriation Assistance Listing Number: 15.U01 Award Number: H.R. 4680/P.L. 114-289 Award Period: October 1, 2023 to September 30, 2024 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of the Federal Funding and Accountability Act (FFATA), which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, the Foundation is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. Condition – During our testing of reporting, we selected fourteen subrecipient awards. For all samples tested, the Foundation did not comply with the mandatory FFATA report filing requirements. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 14 14 14 Not applicable – no report was submitted Not applicable – no report was submitted Dollar Amount of Tested 2024 Subawards Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 4,984,134 $ 4,984,134 $ 4,984,134 Not applicable – no report was submitted Not applicable – no report was submitted Cause - The Foundation did not have adequate policies and procedures in place to ensure compliance with the FFATA filing requirements. Effect or Potential Effect - Failure to comply with the reporting requirements of the Uniform Guidance could result in noncompliance and awarding agency taking administrative action. Questioned Costs – None. Context - This is a condition identified based upon our review of the Foundation’s compliance with specified requirements. The sample was selected based on a non-statistical basis. The prevalence of these finding is detailed in the condition section above. Repeat Finding – This is a repeat finding from prior year. This was reported as finding 2023-003 in the 2023 report. Recommendation – BDO noted management’s actions to address prior year finding, however, the Foundation’s grant agreement do not have a Federal Award Identification Number (FAIN) which is a requirement to file FFATA, management is still unable to file the required FFATA reporting. BDO recommends that the Foundation continue to work with federal grantor/agencies to determine the required information and immediately file the required requirements. Views of Responsible Officials – The Foundation’s management has been given a legal opinion from counsel that the Appropriation and the Endowment are exempt from Uniform Guidance and the Single Audit. As such, will continue to work with Department of Interior to remedy this situation. The planned corrective actions are presented in the Foundation’s management’s corrective action plan attached as Appendix C.
2024-002 Internal Controls over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Requirements (Significant Deficiency) Information on the Federal Program: U.S. Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA22GR00225 May 13, 2022 through May 10, 2024 720BHA22GR00127 April 15, 2022 through April 14, 2024 Criteria or Specific Requirement: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D ‐ Post Federal Award Requirements, Section 200.303 ‐ Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework”, issued by the COSO. In accordance with 2 CFR §200. 308, 200.309, and 200.403(h), a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. A period of performance may contain one or more budget periods. Condition: During our testing of the activities allowed or unallowed and allowable costs/cost principles compliance requirements, we identified one disbursement sample out of a total of twenty-five disbursement samples tested wherein management charged the federal program on June 2024 when the transaction happened on December 2022. In particular, the inventory distribution in the amount of $4,258.53 that took place in December 2022 should have been recorded as an expense in fiscal year 2023 rather than in fiscal year 2024. In addition, during our testing of period of performance compliance requirements, we also noted another inventory distribution in the amount of $235.89 that took place on August 2023 but it was only recorded on June 2024. The expenditures are allowable and within the period of performance, however, the controls over timely reconciliation and recording the inventory distributions did not occur in the appropriate reporting period. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS’s compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: Delays in performing the reconciliation and timely recording of inventory distributions in certain CRS country offices were caused by personnel’s unfamiliarity with the use of the new Supply Chain Management system, a system used in inventory management. Effect: Failure to timely reconcile and record transactions in the correct accounting period results in incorrect SEFA reporting to the U.S. government. Repeat Finding: No. Recommendation: We recommend that management ensure timely reconciliation of inventory distributions in order to record the transactions in the correct accounting period. In addition, management should conduct appropriate training to CRS country office personnel with the proper use of the Supply Chain Management system to ensure timely reconciliation and recording of inventory distributions. Views of Responsible Officials: CRS management agrees with the finding and recommendations and will enhance the inventory reconciliation processes.
2024-002 Internal Controls over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Requirements (Significant Deficiency) Information on the Federal Program: U.S. Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA22GR00225 May 13, 2022 through May 10, 2024 720BHA22GR00127 April 15, 2022 through April 14, 2024 Criteria or Specific Requirement: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D ‐ Post Federal Award Requirements, Section 200.303 ‐ Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework”, issued by the COSO. In accordance with 2 CFR §200. 308, 200.309, and 200.403(h), a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. A period of performance may contain one or more budget periods. Condition: During our testing of the activities allowed or unallowed and allowable costs/cost principles compliance requirements, we identified one disbursement sample out of a total of twenty-five disbursement samples tested wherein management charged the federal program on June 2024 when the transaction happened on December 2022. In particular, the inventory distribution in the amount of $4,258.53 that took place in December 2022 should have been recorded as an expense in fiscal year 2023 rather than in fiscal year 2024. In addition, during our testing of period of performance compliance requirements, we also noted another inventory distribution in the amount of $235.89 that took place on August 2023 but it was only recorded on June 2024. The expenditures are allowable and within the period of performance, however, the controls over timely reconciliation and recording the inventory distributions did not occur in the appropriate reporting period. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS’s compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: Delays in performing the reconciliation and timely recording of inventory distributions in certain CRS country offices were caused by personnel’s unfamiliarity with the use of the new Supply Chain Management system, a system used in inventory management. Effect: Failure to timely reconcile and record transactions in the correct accounting period results in incorrect SEFA reporting to the U.S. government. Repeat Finding: No. Recommendation: We recommend that management ensure timely reconciliation of inventory distributions in order to record the transactions in the correct accounting period. In addition, management should conduct appropriate training to CRS country office personnel with the proper use of the Supply Chain Management system to ensure timely reconciliation and recording of inventory distributions. Views of Responsible Officials: CRS management agrees with the finding and recommendations and will enhance the inventory reconciliation processes.
2024-003 Internal Controls over Compliance and Compliance with Period of Performance Requirement (Significant Deficiency) Information on the Federal Program: U.S. Department of Agriculture Assistance Listing Number: 10.612 Assistance Listing Name: USDA Local and Regional Food Aid Procurement Program Grant Award Number: Direct Award Number Award Period LRP-686-2019/015-00-A October 1, 2019 through September 30, 2024 Criteria or Specific Requirement: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D ‐ Post Federal Award Requirements, Section 200.303 ‐ Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework”, issued by the COSO. In accordance with 2 CFR §200. 308, 200.309, and 200.403(h), a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. A period of performance may contain one or more budget periods. Condition: During our testing of the period of performance compliance requirements, we identified two disbursement samples for a total of $1,574.09 out of a total of twenty-five disbursement samples tested wherein management was unable to provide evidence that the expenditures charged to the program were valid and incurred within the appropriate period of performance. Management also subsequently concluded that these transactions should have been captured as inventory and not charged as expenditure to the federal program. Questioned Costs: $1,574.09 from our samples. Context: This is a condition based on testing of CRS’s compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method. The total amount of the twenty-five samples selected for testing was $62,914. Cause: CRS country office personnel did not adhere to CRS’s documented policies and procedures for ensuring only valid and allowable expenses are charged to the federal program within the appropriate period of performance. Effect: Without adequate internal controls in place to ensure costs are properly reviewed for allowability and appropriate period of performance, CRS could be noncompliant with the allowability and period of performance requirements and could request funds for costs that are unallowed. Repeat Finding: No. Recommendation: We recommend that management follow its own policies, procedures and controls to ensure that the inventory expenses charged to the federal program are allowable within the period of performance. Views of Responsible Officials: CRS management agrees with the finding and recommendations and will enhance processes around inventory expense allowability.
2024-004 Internal Controls over Compliance and Compliance with Equipment and Real Property Management (Significant Deficiency) Information on the Federal Program: U.S. Department of Agriculture Assistance Listing Number: 10.606 Assistance Listing Name: Food for Progress Grant Award Number: Direct Award Number Award Period FCC-521-2016/012-00 September 29, 2016 through September 30, 2025 Criteria or Specific Requirement: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D ‐ Post Federal Award Requirements, Section 200.303 ‐ Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework”, issued by the COSO. Also, a physical inventory of property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Condition: During our testing of the equipment and real property management compliance requirements, we noted that there is no formally documented physical count of property acquired using federal funds in 2024 specific to Haiti. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS’s compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS country office personnel did not adhere to CRS’s documented policies and procedures for ensuring proper compliance with monitoring of property acquired using federal funds. Effect: Failure to conduct physical inventory of property could lead to misappropriation of assets and noncompliance with Federal regulations resulting in return of Federal awards received. Repeat Finding: No. Recommendation: We recommend that management implement policies, procedures and controls that will ensure the physical counts of property are conducted, that evidence of a count is formally documented and an authorized individual formally approves the result of the count, and the related reconciliation of property records, in order to adhere to Federal regulations related to equipment management and its related maintenance. Views of Responsible Officials: CRS management agrees with the finding and recommendations and will enhance processes surrounding property reconciliation.
Criteria: According to §200.303 Internal controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to the Uniform Guidance (2 CFR Part 200), specifically §200.400 - 200.475, costs charged to federal awards must be reasonable, allocable, and allowable under the terms of the award. Condition and Context: Management was unable to provide sufficient documentation for specific COVID-19 expenditures that were initially reported on the Schedule of Expenditures of Federal Awards. As a result, audit adjustments were necessary to revise the total COVID-19 expenditures to include only those amounts that could be adequately substantiated. Cause: The lack of sufficient documentation was primarily due to a lack of adequate internal controls and oversight regarding the classification and allocation of COVID-19 expenditures charged to federal awards. Effect: Management did not have sufficient documentation to support activities met the terms and conditions related to the COVID-19 Indian Self-Determination federal awards. Audit adjustments were necessary to revise the total COVID-19 expenditures to include only those amounts that could be adequately substantiated. Questioned Cost: None. Repeat Finding: No Recommendation: We recommend the Hospital establish and document clear policies and procedures for identifying, classifying, and allocating costs charged to federal awards, ensuring compliance with the Uniform Guidance. Additionally, we recommend the Hospital conduct regular reviews of expenditures charged to federal awards to ensure compliance with federal regulations and the terms of the awards. Views of Responsible Officials: The Finance team of Financial Controller and Senior Accountant are responsible for gathering sufficient documentation specific to COVID-19 expenditures. Proper and accurate classification and allocation of COVID-19 related activities and expenditures will be tracked and monitored before charging to funds. This will be completed by September 30, 2025.
U.S. Department of Agriculture Federal Assistance Listing #10.766 Community Facilities Loans and Grants Applicable Federal Award Number – Direct Loan and Guaranteed Loan Special Tests and Provisions Significant Deficiency in Internal Control Over Compliance and Noncompliance Not Considered Material Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Medical Center was required to establish reserve accounts with deposits equal to 10% of the annual debt service requirement on the direct loan and guaranteed loan for the entire year. The Medical Center did not establish these accounts until August 2024. Although the reserve was fully funded by year-end, the reserve was not funded the entire year, as required. Cause: This deficiency is due to a misunderstanding of establishing reserve accounts as Salina Regional Health Center is the centralized cash management agent for the Medical Center. Once this was identified, the Medical Center worked with the bank to establish a reserve. Effect: The Medical Center was not in compliance with the terms of the loan agreements related to the reserve funds until August 2024. Questioned Costs: None. Context: Sampling was not used. Repeat Finding from Prior Years: Yes. Recommendation: We recommend management implement a control process to ensure the reserve is fully funded throughout the entire year. Views of Responsible Officials: Management agrees with the finding.
2024-002 Procurement Space Operations Assistance Listing Number: 43.007 Federal Award ID Number: 80JSC018M0005 National Aeronautics and Space Administration 2024 Funding, Repeat Finding Criteria: 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. 2 CFR Section 200.320 and 48 CFR section 52.244-5 sets forth the requirements for acquisition contracts awarded to vendors including the requirement to obtain price or rate quotations from an adequate number of qualified sources and the circumstances in which noncompetitive procurement methods can be used. Also, CASIS’s procurement policy states that it is in both CASIS and NASA’s interest to compete when it makes sense regardless of the threshold and can be achieved by obtaining three quotes, i.e., comparative shopping. A minimum of 3 vendors are required to demonstrate competition. CASIS may solicit a proposal from only one source in circumstances where one or more of the following conditions apply (FAR Subpart 6.3): (i) The item or service is available only from a single source. supplies or services to be procured immediately. (iii) NASA specifically authorizes the use of noncompetitive proposals (directed source). (iv) After consultation with a number of sources, competition is determined inadequate. (v) The vendor is listed as a sole source provider under the Cooperative Agreement. Condition: Sole source determination was not documented for two vendors. Cause: For two legal expenses tested in the sample, no documentation of this being a sole source purchase prior to expending the funds. Effect: If CASIS cannot demonstrate that procurement of services were properly sole sourced, this may result in questioned costs and funds being returned to NASA. Questioned Costs: Known questioned costs of $41,762 and likely questioned costs of $90,024. Perspective: There were 2 out of 60 expenses selected for which the control failed. Recommendation: Non-competitive procurement should be documented and approved prior to incurring expenses. Management Response: CASIS acknowledges the error documenting these procurements. The two legal service vendors had been discussed internally and the selections rationalized based on the specialty of the professional services required for leasing and employment matters. Unfortunately, the documentation was not completed and stored as required by our internal policies. We consider these costs to be both necessary and reasonable, as we were negotiating a new office space lease and the rates were consistent with other legal service providers that CASIS has procured. CASIS plans on reinforcing the procurement documentation requirements with our personnel through additional training and reminding that engagement letters need to go through our document review software.
U.S. Department of Energy 2024-001 – Weatherization Assistance for Low-Income Persons (Weatherization) – Assistance Listing No. 81.042, Passed through the Commonwealth of Massachusetts, Pass-through identifying number CT OCD SCOCD410024330000301, Grant Period – Year Ended June 30, 2025. Condition: Action, Inc. (the Agency) did not follow its internal controls regarding the monthly reporting for the Weatherization grant and as a result, the Agency included private utility grant costs within one of the Agency’s Weatherization monthly reports to the grantor for which the Agency was reimbursed for. Criteria: 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. In addition, the Agency can only request federal reimbursement for federally incurred allowable costs. Cause: The Agency did not properly follow its internal controls. Effect: The Agency did not follow its internal controls for reporting a federal reimbursement request for one month and included non-federal charges within the reimbursement request. Context: One out of seven monthly reports sampled. Our sample was not a statistically valid sample. This was not a repeat finding from a prior period. Questioned Costs: None Recommendations: Management should ensure that the Agency’s internal controls in place are properly followed. Management Response: Management agrees with the finding. During the year, the Agency had staff turnover which was one factor of the reporting error. Management will enhance its internal controls to ensure that monthly reporting only reflects federally related activity.
U.S. Department of Energy 2024-001 – Weatherization Assistance for Low-Income Persons (Weatherization) – Assistance Listing No. 81.042, Passed through the Commonwealth of Massachusetts, Pass-through identifying number CT OCD SCOCD410024330000301, Grant Period – Year Ended June 30, 2025. Condition: Action, Inc. (the Agency) did not follow its internal controls regarding the monthly reporting for the Weatherization grant and as a result, the Agency included private utility grant costs within one of the Agency’s Weatherization monthly reports to the grantor for which the Agency was reimbursed for. Criteria: 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. In addition, the Agency can only request federal reimbursement for federally incurred allowable costs. Cause: The Agency did not properly follow its internal controls. Effect: The Agency did not follow its internal controls for reporting a federal reimbursement request for one month and included non-federal charges within the reimbursement request. Context: One out of seven monthly reports sampled. Our sample was not a statistically valid sample. This was not a repeat finding from a prior period. Questioned Costs: None Recommendations: Management should ensure that the Agency’s internal controls in place are properly followed. Management Response: Management agrees with the finding. During the year, the Agency had staff turnover which was one factor of the reporting error. Management will enhance its internal controls to ensure that monthly reporting only reflects federally related activity.
U.S. Department of Energy 2024-001 – Weatherization Assistance for Low-Income Persons (Weatherization) – Assistance Listing No. 81.042, Passed through the Commonwealth of Massachusetts, Pass-through identifying number CT OCD SCOCD410024330000301, Grant Period – Year Ended June 30, 2025. Condition: Action, Inc. (the Agency) did not follow its internal controls regarding the monthly reporting for the Weatherization grant and as a result, the Agency included private utility grant costs within one of the Agency’s Weatherization monthly reports to the grantor for which the Agency was reimbursed for. Criteria: 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. In addition, the Agency can only request federal reimbursement for federally incurred allowable costs. Cause: The Agency did not properly follow its internal controls. Effect: The Agency did not follow its internal controls for reporting a federal reimbursement request for one month and included non-federal charges within the reimbursement request. Context: One out of seven monthly reports sampled. Our sample was not a statistically valid sample. This was not a repeat finding from a prior period. Questioned Costs: None Recommendations: Management should ensure that the Agency’s internal controls in place are properly followed. Management Response: Management agrees with the finding. During the year, the Agency had staff turnover which was one factor of the reporting error. Management will enhance its internal controls to ensure that monthly reporting only reflects federally related activity.
Assistance Listing Number(s): 93.575 Name of Federal Program or Cluster: CCDF Cluster Name of Federal Agency: Department of Health and Human Services Name of Pass-through Entity: Minnesota Department of Human Services Award Period: 7/1/2020-6/30/2024 and 7/1/2024-6/30/2026 Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations (CFR) section 200.303 requires non-federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Condition: The Registry, Inc. did not obtain support from the employee for time and effort used as the basis for allocating personnel costs to federal awards. Cause: The Registry, Inc. did not properly design policies and procedures to ensure time and effort reporting is maintained by employees, adequately and contemporaneously documented, and reviewed by supervisors or managers. Effect or Potential Effect: Costs not supported by adequate documentation could be disallowed. Repeat Finding: No. Recommendation: The Registry, Inc. should obtain time and effort documentation that supports the distribution of the employee's salary or wages among specific activities. The Registry, Inc. should design and implement written policies and procedures for personnel to document time spent on grant activities for every pay period, or monthly at a minimum. Views of Responsible Officials: The Registry, Inc. will implement written policies and procedures for personnel to document time spent on grant activities.