2024-002 Finding – Federal Award Type: Special Reporting - Federal Funding Accountability and Transparency Act (FFATA) – Material Non- Compliance and Material Weakness in Internal Controls over Compliance. (Repeat of finding 2023-003) Identification of Federal Program: AL Number: 64.033 Supportive Services for Veteran Families Criteria / Requirement: 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The subawards meeting the above definition are to be reported no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Condition / Context: During the year June 30, 2024, CAT entered into three first-tier subawards greater than $30,000 under AL number 64.033. The auditor tested one of these subawards, noting that the award was reported late under the Federal Funding Accountability and Transparency Act to the Federal Subaward Reporting System. Per further inquiry, all of the first-tier subawards were reported late to FSRS. CAT was aware of the FFATA reporting requirements, but the timing of the previous year finding did not allow for corrections during the fiscal year 2024. Procedures were not in place to track and report first-tier subawards within the time frame required by federal requirements. Effect: Failure to maintain sufficient internal controls and proper procedures, including identifying compliance requirements of grant agreements and tracking over reporting first-tier subawards may result in wrongful use of federal funds and non-compliance with federal awards. Questioned Costs: None. Recommendation: The Organization should establish written policies and procedures regarding review of grant agreements for compliance requirements along with written policies and procedures for first-tier subawards including tracking and proper internal control procedures. Management’s Response: Management concurs with the finding and has defined corrective action to address it. We have identified gaps in our reporting processes and worked to implement changes to ensure compliance with special reporting requirements. Policies and procedures will be updated regarding special reporting requirements. The Fiscal department will also be responsible for reviewing all contracts to identify all compliance requirements. Tracking procedures will be implemented to ensure reports are filed timely. The above identified corrective action was implemented in July 2024. Stacey Wilson, Fiscal Director, has implemented a tracking system for the FFATA.
2024-004 - Allowable Cost/Cost Principles Federal Program Information: Department of Treasury - State & Local Fiscal Recovery Fund ALN - 21.027 - State & Local Fiscal Recovery Fund Criteria: The following CFR(s) apply to this finding: 2 CFR §200.303 Condition: During our testing of 9 disbursements under the State & Local Fiscal Recovery Funds, we noted that 4 disbursements totaling $460,844 were approved without following the City’s documented internal control procedures. Specifically, the City’s policy requires documenting the approval of invoices, but this process was not followed for the identified transactions. Cause: The control lapse occurred because there was turnover in key positions. Effect: By not following its own internal control procedures, the City increased the risk of unallowable or unsupported costs being charged to the program. Although we did not identify any unallowable costs in the items tested, the absence of proper approvals diminishes assurance that expenses are appropriate and compliant. Identification of Questioned Costs: None identified. Context: The entire population of 12 months of reimbursements from the fiscal year were examined which is a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the City implement internal control processes and procedures to ensure that all invoices are approved per the City’s policy. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the City.
2024-004 - Allowable Cost/Cost Principles Federal Program Information: Department of Treasury - State & Local Fiscal Recovery Fund ALN - 21.027 - State & Local Fiscal Recovery Fund Criteria: The following CFR(s) apply to this finding: 2 CFR §200.303 Condition: During our testing of 9 disbursements under the State & Local Fiscal Recovery Funds, we noted that 4 disbursements totaling $460,844 were approved without following the City’s documented internal control procedures. Specifically, the City’s policy requires documenting the approval of invoices, but this process was not followed for the identified transactions. Cause: The control lapse occurred because there was turnover in key positions. Effect: By not following its own internal control procedures, the City increased the risk of unallowable or unsupported costs being charged to the program. Although we did not identify any unallowable costs in the items tested, the absence of proper approvals diminishes assurance that expenses are appropriate and compliant. Identification of Questioned Costs: None identified. Context: The entire population of 12 months of reimbursements from the fiscal year were examined which is a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the City implement internal control processes and procedures to ensure that all invoices are approved per the City’s policy. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the City.
2024-004 - Allowable Cost/Cost Principles Federal Program Information: Department of Treasury - State & Local Fiscal Recovery Fund ALN - 21.027 - State & Local Fiscal Recovery Fund Criteria: The following CFR(s) apply to this finding: 2 CFR §200.303 Condition: During our testing of 9 disbursements under the State & Local Fiscal Recovery Funds, we noted that 4 disbursements totaling $460,844 were approved without following the City’s documented internal control procedures. Specifically, the City’s policy requires documenting the approval of invoices, but this process was not followed for the identified transactions. Cause: The control lapse occurred because there was turnover in key positions. Effect: By not following its own internal control procedures, the City increased the risk of unallowable or unsupported costs being charged to the program. Although we did not identify any unallowable costs in the items tested, the absence of proper approvals diminishes assurance that expenses are appropriate and compliant. Identification of Questioned Costs: None identified. Context: The entire population of 12 months of reimbursements from the fiscal year were examined which is a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the City implement internal control processes and procedures to ensure that all invoices are approved per the City’s policy. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the City.
Finding 2024-003 – Preparation of Schedule of Expenditures of Federal Awards (SEFA) (Material Weakness) (Repeat Finding) Program: All Assistance Listing (AL) No.: N/A Federal Agency: N/A Passed Through: N/A Award Year: Fiscal Year 2023-2024 Compliance Requirement: N/A Questioned Costs: None Criteria Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the Agency) must prepare a SEFA for the period covered by the auditee’s financial statements, which must include the total federal awards expended as determined in accordance with §200.502. In addition, §200.303 of the Uniform Guidance states that the Agency must establish and maintain effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition During audit procedures performed over the SEFA, we noted that the Agency incorrectly included Federal expenditures from AL No. 20.507 and AL No. 20.509 that were accrued and recorded in fiscal year 2023 in the amount of $2,160,408, and excluded expenditures from AL No. 20.507 Federal Transit Formula Grants in the amount of $2,924,012 and 20.509 Formula Grants for Rural Areas and Tribal Transit Program in the amount of $2,259,151 on its preliminary SEFA. Cause of Condition The Agency’s existing internal control system is not designed to provide an accurate and complete SEFA. The procedures currently in place did not include sufficient review of the information and supporting documentation relating to federal awards before the SEFA was provided to the external auditors. The first version of the SEFA provided by the Agency reported total expenditures of $2,842,283; the final revised expenditures totaled $5,865,038. Effect of Condition The SEFA, which is prepared by the Agency and considered supplementary information to the financial statements, is a key part of the reporting package required by the Uniform Guidance. The SEFA also serves as the primary basis that the external auditors use to determine which programs will be audited as part of the single audit; therefore, the Agency’s responsibility for preparing an accurate and complete SEFA is critical. The inability to properly identify and track federal expenditures in the SEFA increases the likelihood that federal expenditures would not be fairly reported. There is increased risk of noncompliance with the requirements set forth in the U.S. Office of Management and Budget (OMB) Compliance Supplement, which can jeopardize future federal funding as well as result in the payback of federal awards. Recommendation We recommend the Agency implement internal controls to ensure the accuracy of program information, expenditure amounts, and assistance listing numbers. We also recommend the Agency strengthen its year-end closing procedures to ensure that all transactions and federal awards related to the fiscal year are properly captured and recorded in the general ledger to ensure the accuracy and completeness of the financial statements and supplementary schedules. Additionally, we recommend that the Agency provide sufficient resources and adequate oversight within the Agency to oversee the year-end closing procedures and preparation of the financial statements and supporting schedules. Lastly, we recommend the Agency provide training on an as needed basis for employees with financial reporting responsibilities. Management Response and Corrective Action Plan We acknowledge the findings regarding the preparation of the Schedule of Expenditures of Federal Awards (SEFA). Management agrees that there were errors in the classification and reporting of federal expenditures during the fiscal year 2023-2024, which resulted from inadequate review controls and documentation procedures. The Agency is committed to enhancing internal controls and year-end closing processes to ensure that the SEFA is complete, accurate, and compliant with 2 CFR Part 200 requirements.
Finding 2024-003 – Preparation of Schedule of Expenditures of Federal Awards (SEFA) (Material Weakness) (Repeat Finding) Program: All Assistance Listing (AL) No.: N/A Federal Agency: N/A Passed Through: N/A Award Year: Fiscal Year 2023-2024 Compliance Requirement: N/A Questioned Costs: None Criteria Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the Agency) must prepare a SEFA for the period covered by the auditee’s financial statements, which must include the total federal awards expended as determined in accordance with §200.502. In addition, §200.303 of the Uniform Guidance states that the Agency must establish and maintain effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition During audit procedures performed over the SEFA, we noted that the Agency incorrectly included Federal expenditures from AL No. 20.507 and AL No. 20.509 that were accrued and recorded in fiscal year 2023 in the amount of $2,160,408, and excluded expenditures from AL No. 20.507 Federal Transit Formula Grants in the amount of $2,924,012 and 20.509 Formula Grants for Rural Areas and Tribal Transit Program in the amount of $2,259,151 on its preliminary SEFA. Cause of Condition The Agency’s existing internal control system is not designed to provide an accurate and complete SEFA. The procedures currently in place did not include sufficient review of the information and supporting documentation relating to federal awards before the SEFA was provided to the external auditors. The first version of the SEFA provided by the Agency reported total expenditures of $2,842,283; the final revised expenditures totaled $5,865,038. Effect of Condition The SEFA, which is prepared by the Agency and considered supplementary information to the financial statements, is a key part of the reporting package required by the Uniform Guidance. The SEFA also serves as the primary basis that the external auditors use to determine which programs will be audited as part of the single audit; therefore, the Agency’s responsibility for preparing an accurate and complete SEFA is critical. The inability to properly identify and track federal expenditures in the SEFA increases the likelihood that federal expenditures would not be fairly reported. There is increased risk of noncompliance with the requirements set forth in the U.S. Office of Management and Budget (OMB) Compliance Supplement, which can jeopardize future federal funding as well as result in the payback of federal awards. Recommendation We recommend the Agency implement internal controls to ensure the accuracy of program information, expenditure amounts, and assistance listing numbers. We also recommend the Agency strengthen its year-end closing procedures to ensure that all transactions and federal awards related to the fiscal year are properly captured and recorded in the general ledger to ensure the accuracy and completeness of the financial statements and supplementary schedules. Additionally, we recommend that the Agency provide sufficient resources and adequate oversight within the Agency to oversee the year-end closing procedures and preparation of the financial statements and supporting schedules. Lastly, we recommend the Agency provide training on an as needed basis for employees with financial reporting responsibilities. Management Response and Corrective Action Plan We acknowledge the findings regarding the preparation of the Schedule of Expenditures of Federal Awards (SEFA). Management agrees that there were errors in the classification and reporting of federal expenditures during the fiscal year 2023-2024, which resulted from inadequate review controls and documentation procedures. The Agency is committed to enhancing internal controls and year-end closing processes to ensure that the SEFA is complete, accurate, and compliant with 2 CFR Part 200 requirements.
Finding 2024-003 – Preparation of Schedule of Expenditures of Federal Awards (SEFA) (Material Weakness) (Repeat Finding) Program: All Assistance Listing (AL) No.: N/A Federal Agency: N/A Passed Through: N/A Award Year: Fiscal Year 2023-2024 Compliance Requirement: N/A Questioned Costs: None Criteria Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the Agency) must prepare a SEFA for the period covered by the auditee’s financial statements, which must include the total federal awards expended as determined in accordance with §200.502. In addition, §200.303 of the Uniform Guidance states that the Agency must establish and maintain effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition During audit procedures performed over the SEFA, we noted that the Agency incorrectly included Federal expenditures from AL No. 20.507 and AL No. 20.509 that were accrued and recorded in fiscal year 2023 in the amount of $2,160,408, and excluded expenditures from AL No. 20.507 Federal Transit Formula Grants in the amount of $2,924,012 and 20.509 Formula Grants for Rural Areas and Tribal Transit Program in the amount of $2,259,151 on its preliminary SEFA. Cause of Condition The Agency’s existing internal control system is not designed to provide an accurate and complete SEFA. The procedures currently in place did not include sufficient review of the information and supporting documentation relating to federal awards before the SEFA was provided to the external auditors. The first version of the SEFA provided by the Agency reported total expenditures of $2,842,283; the final revised expenditures totaled $5,865,038. Effect of Condition The SEFA, which is prepared by the Agency and considered supplementary information to the financial statements, is a key part of the reporting package required by the Uniform Guidance. The SEFA also serves as the primary basis that the external auditors use to determine which programs will be audited as part of the single audit; therefore, the Agency’s responsibility for preparing an accurate and complete SEFA is critical. The inability to properly identify and track federal expenditures in the SEFA increases the likelihood that federal expenditures would not be fairly reported. There is increased risk of noncompliance with the requirements set forth in the U.S. Office of Management and Budget (OMB) Compliance Supplement, which can jeopardize future federal funding as well as result in the payback of federal awards. Recommendation We recommend the Agency implement internal controls to ensure the accuracy of program information, expenditure amounts, and assistance listing numbers. We also recommend the Agency strengthen its year-end closing procedures to ensure that all transactions and federal awards related to the fiscal year are properly captured and recorded in the general ledger to ensure the accuracy and completeness of the financial statements and supplementary schedules. Additionally, we recommend that the Agency provide sufficient resources and adequate oversight within the Agency to oversee the year-end closing procedures and preparation of the financial statements and supporting schedules. Lastly, we recommend the Agency provide training on an as needed basis for employees with financial reporting responsibilities. Management Response and Corrective Action Plan We acknowledge the findings regarding the preparation of the Schedule of Expenditures of Federal Awards (SEFA). Management agrees that there were errors in the classification and reporting of federal expenditures during the fiscal year 2023-2024, which resulted from inadequate review controls and documentation procedures. The Agency is committed to enhancing internal controls and year-end closing processes to ensure that the SEFA is complete, accurate, and compliant with 2 CFR Part 200 requirements.
Finding 2024-003 – Preparation of Schedule of Expenditures of Federal Awards (SEFA) (Material Weakness) (Repeat Finding) Program: All Assistance Listing (AL) No.: N/A Federal Agency: N/A Passed Through: N/A Award Year: Fiscal Year 2023-2024 Compliance Requirement: N/A Questioned Costs: None Criteria Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the Agency) must prepare a SEFA for the period covered by the auditee’s financial statements, which must include the total federal awards expended as determined in accordance with §200.502. In addition, §200.303 of the Uniform Guidance states that the Agency must establish and maintain effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition During audit procedures performed over the SEFA, we noted that the Agency incorrectly included Federal expenditures from AL No. 20.507 and AL No. 20.509 that were accrued and recorded in fiscal year 2023 in the amount of $2,160,408, and excluded expenditures from AL No. 20.507 Federal Transit Formula Grants in the amount of $2,924,012 and 20.509 Formula Grants for Rural Areas and Tribal Transit Program in the amount of $2,259,151 on its preliminary SEFA. Cause of Condition The Agency’s existing internal control system is not designed to provide an accurate and complete SEFA. The procedures currently in place did not include sufficient review of the information and supporting documentation relating to federal awards before the SEFA was provided to the external auditors. The first version of the SEFA provided by the Agency reported total expenditures of $2,842,283; the final revised expenditures totaled $5,865,038. Effect of Condition The SEFA, which is prepared by the Agency and considered supplementary information to the financial statements, is a key part of the reporting package required by the Uniform Guidance. The SEFA also serves as the primary basis that the external auditors use to determine which programs will be audited as part of the single audit; therefore, the Agency’s responsibility for preparing an accurate and complete SEFA is critical. The inability to properly identify and track federal expenditures in the SEFA increases the likelihood that federal expenditures would not be fairly reported. There is increased risk of noncompliance with the requirements set forth in the U.S. Office of Management and Budget (OMB) Compliance Supplement, which can jeopardize future federal funding as well as result in the payback of federal awards. Recommendation We recommend the Agency implement internal controls to ensure the accuracy of program information, expenditure amounts, and assistance listing numbers. We also recommend the Agency strengthen its year-end closing procedures to ensure that all transactions and federal awards related to the fiscal year are properly captured and recorded in the general ledger to ensure the accuracy and completeness of the financial statements and supplementary schedules. Additionally, we recommend that the Agency provide sufficient resources and adequate oversight within the Agency to oversee the year-end closing procedures and preparation of the financial statements and supporting schedules. Lastly, we recommend the Agency provide training on an as needed basis for employees with financial reporting responsibilities. Management Response and Corrective Action Plan We acknowledge the findings regarding the preparation of the Schedule of Expenditures of Federal Awards (SEFA). Management agrees that there were errors in the classification and reporting of federal expenditures during the fiscal year 2023-2024, which resulted from inadequate review controls and documentation procedures. The Agency is committed to enhancing internal controls and year-end closing processes to ensure that the SEFA is complete, accurate, and compliant with 2 CFR Part 200 requirements.
Finding 2024-003 – Preparation of Schedule of Expenditures of Federal Awards (SEFA) (Material Weakness) (Repeat Finding) Program: All Assistance Listing (AL) No.: N/A Federal Agency: N/A Passed Through: N/A Award Year: Fiscal Year 2023-2024 Compliance Requirement: N/A Questioned Costs: None Criteria Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the Agency) must prepare a SEFA for the period covered by the auditee’s financial statements, which must include the total federal awards expended as determined in accordance with §200.502. In addition, §200.303 of the Uniform Guidance states that the Agency must establish and maintain effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition During audit procedures performed over the SEFA, we noted that the Agency incorrectly included Federal expenditures from AL No. 20.507 and AL No. 20.509 that were accrued and recorded in fiscal year 2023 in the amount of $2,160,408, and excluded expenditures from AL No. 20.507 Federal Transit Formula Grants in the amount of $2,924,012 and 20.509 Formula Grants for Rural Areas and Tribal Transit Program in the amount of $2,259,151 on its preliminary SEFA. Cause of Condition The Agency’s existing internal control system is not designed to provide an accurate and complete SEFA. The procedures currently in place did not include sufficient review of the information and supporting documentation relating to federal awards before the SEFA was provided to the external auditors. The first version of the SEFA provided by the Agency reported total expenditures of $2,842,283; the final revised expenditures totaled $5,865,038. Effect of Condition The SEFA, which is prepared by the Agency and considered supplementary information to the financial statements, is a key part of the reporting package required by the Uniform Guidance. The SEFA also serves as the primary basis that the external auditors use to determine which programs will be audited as part of the single audit; therefore, the Agency’s responsibility for preparing an accurate and complete SEFA is critical. The inability to properly identify and track federal expenditures in the SEFA increases the likelihood that federal expenditures would not be fairly reported. There is increased risk of noncompliance with the requirements set forth in the U.S. Office of Management and Budget (OMB) Compliance Supplement, which can jeopardize future federal funding as well as result in the payback of federal awards. Recommendation We recommend the Agency implement internal controls to ensure the accuracy of program information, expenditure amounts, and assistance listing numbers. We also recommend the Agency strengthen its year-end closing procedures to ensure that all transactions and federal awards related to the fiscal year are properly captured and recorded in the general ledger to ensure the accuracy and completeness of the financial statements and supplementary schedules. Additionally, we recommend that the Agency provide sufficient resources and adequate oversight within the Agency to oversee the year-end closing procedures and preparation of the financial statements and supporting schedules. Lastly, we recommend the Agency provide training on an as needed basis for employees with financial reporting responsibilities. Management Response and Corrective Action Plan We acknowledge the findings regarding the preparation of the Schedule of Expenditures of Federal Awards (SEFA). Management agrees that there were errors in the classification and reporting of federal expenditures during the fiscal year 2023-2024, which resulted from inadequate review controls and documentation procedures. The Agency is committed to enhancing internal controls and year-end closing processes to ensure that the SEFA is complete, accurate, and compliant with 2 CFR Part 200 requirements.
FA 2024-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Numbers: 245GA324N1199 (Year: 2024), 235GA32N1099 (Year: 2023) Questioned Costs: $7,388 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that expenditures were reviewed and approved and that the School District’s procurement and suspension and debarment procedures were followed. Background Information: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential childcare institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $1,087,437.24 were expended and reported on the Wilkinson County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2024. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 – Factors Affecting Allowability of Costs state that “costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity… (g) Be adequately documented…” Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.” Condition: A sample of 39 expenditures was randomly selected for testing using a non-statistical sampling approach. These expenditures were reviewed to determine if appropriate internal controls were implemented and applicable compliance requirements were met. For eight of the 10 sample expenditures that were incurred outside of the School District’s Co-Op process, evidence of review and approval was not reflected within the voucher package. Additionally, auditor reviewed five of these same expenditures and a sample of 29 additional expenditures, which was randomly selected for testing using a non-statistical sampling approach, to determine if procurement transactions complied with the School District’s procurement procedures and proper oversight was maintained to ensure that contractors were performing according to their contracts. The following deficiencies were noted with expenditures incurred outside of the School District’s Co-Op process: • Evidence of review and approval was not reflected within the voucher package and/or purchase files for 17 additional expenditures. • The School District could not provide evidence that an adequate number of rate or price quotations were obtained from qualified sources for eight small purchase expenditures reviewed. Questioned Costs: Upon testing a sample of $14,237 in procurement transactions that were incurred outside of the School District’s Co-Op process, known questioned costs of $7,388 were identified for expenditures that did not follow the School District’s procurement procedures. Using the population of procurements that were incurred outside of the School District’s Co-Op process of $56,274, we project the likely questioned costs to be approximately $29,200. Cause: The School District did not follow its policies and procedures that govern the nonpersonal services expenditure process for federal programs. Effect: The School District is not in compliance with the Uniform Guidance and GaDOE guidance related to CNC. Failure to ensure that expenditures are appropriately approved and procedures to address procurement and suspension and debarment compliance requirements are implemented exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds for unallowable purposes and/or with unqualified vendors. In addition, this deficiency could lead to the return of funding associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to CNC. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that all expenditures reflect evidence of review and approval, required procurement methods are properly identified and followed and required procurement and suspension and debarment documentation is properly identified, safeguarded, and retained. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding.
FA 2024-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Numbers: 245GA324N1199 (Year: 2024), 235GA32N1099 (Year: 2023) Questioned Costs: $7,388 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that expenditures were reviewed and approved and that the School District’s procurement and suspension and debarment procedures were followed. Background Information: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential childcare institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $1,087,437.24 were expended and reported on the Wilkinson County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2024. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 – Factors Affecting Allowability of Costs state that “costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity… (g) Be adequately documented…” Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.” Condition: A sample of 39 expenditures was randomly selected for testing using a non-statistical sampling approach. These expenditures were reviewed to determine if appropriate internal controls were implemented and applicable compliance requirements were met. For eight of the 10 sample expenditures that were incurred outside of the School District’s Co-Op process, evidence of review and approval was not reflected within the voucher package. Additionally, auditor reviewed five of these same expenditures and a sample of 29 additional expenditures, which was randomly selected for testing using a non-statistical sampling approach, to determine if procurement transactions complied with the School District’s procurement procedures and proper oversight was maintained to ensure that contractors were performing according to their contracts. The following deficiencies were noted with expenditures incurred outside of the School District’s Co-Op process: • Evidence of review and approval was not reflected within the voucher package and/or purchase files for 17 additional expenditures. • The School District could not provide evidence that an adequate number of rate or price quotations were obtained from qualified sources for eight small purchase expenditures reviewed. Questioned Costs: Upon testing a sample of $14,237 in procurement transactions that were incurred outside of the School District’s Co-Op process, known questioned costs of $7,388 were identified for expenditures that did not follow the School District’s procurement procedures. Using the population of procurements that were incurred outside of the School District’s Co-Op process of $56,274, we project the likely questioned costs to be approximately $29,200. Cause: The School District did not follow its policies and procedures that govern the nonpersonal services expenditure process for federal programs. Effect: The School District is not in compliance with the Uniform Guidance and GaDOE guidance related to CNC. Failure to ensure that expenditures are appropriately approved and procedures to address procurement and suspension and debarment compliance requirements are implemented exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds for unallowable purposes and/or with unqualified vendors. In addition, this deficiency could lead to the return of funding associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to CNC. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that all expenditures reflect evidence of review and approval, required procurement methods are properly identified and followed and required procurement and suspension and debarment documentation is properly identified, safeguarded, and retained. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding.
2 CFR 200.303 requires Non-Federal entities must establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. During fiscal year 2024, the District participated in Child Nutrition Cluster programs, for which the federal government reimburses the District for eligible children. During the school year, the School District is required to establish a child's eligibility to receive program benefits. The District accepted online applications for free and reduced meals, with which eligibility was determined based on several factors, including, but not limited to family size and income. For fiscal year 2024, the eligibility process was 100% online through PaySchools to determine eligibility for free and reduced meals. The option selected within PaySchools by the District was for the portal applications uploaded from RocketScan to be approved as entered (if the eligibility criteria was met) with no additional review, rather than applications being in pending status until reviewed and approved by the District. As such, the District had no procedures in place to ensure the system determined the proper eligibility status based on the information provided in the application. Failure to implement controls over all eligibility applications could result in ineligible students receiving benefits. The District should implement control procedures for online applications to help ensure students are properly marked as paid, free or reduced.
2 CFR 200.303 requires Non-Federal entities must establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. During fiscal year 2024, the District participated in Child Nutrition Cluster programs, for which the federal government reimburses the District for eligible children. During the school year, the School District is required to establish a child's eligibility to receive program benefits. The District accepted online applications for free and reduced meals, with which eligibility was determined based on several factors, including, but not limited to family size and income. For fiscal year 2024, the eligibility process was 100% online through PaySchools to determine eligibility for free and reduced meals. The option selected within PaySchools by the District was for the portal applications uploaded from RocketScan to be approved as entered (if the eligibility criteria was met) with no additional review, rather than applications being in pending status until reviewed and approved by the District. As such, the District had no procedures in place to ensure the system determined the proper eligibility status based on the information provided in the application. Failure to implement controls over all eligibility applications could result in ineligible students receiving benefits. The District should implement control procedures for online applications to help ensure students are properly marked as paid, free or reduced.
2 CFR 200.303 requires Non-Federal entities must establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. During fiscal year 2024, the District participated in Child Nutrition Cluster programs, for which the federal government reimburses the District for eligible children. During the school year, the School District is required to establish a child's eligibility to receive program benefits. The District accepted online applications for free and reduced meals, with which eligibility was determined based on several factors, including, but not limited to family size and income. For fiscal year 2024, the eligibility process was 100% online through PaySchools to determine eligibility for free and reduced meals. The option selected within PaySchools by the District was for the portal applications uploaded from RocketScan to be approved as entered (if the eligibility criteria was met) with no additional review, rather than applications being in pending status until reviewed and approved by the District. As such, the District had no procedures in place to ensure the system determined the proper eligibility status based on the information provided in the application. Failure to implement controls over all eligibility applications could result in ineligible students receiving benefits. The District should implement control procedures for online applications to help ensure students are properly marked as paid, free or reduced.
2 CFR 200.303 requires Non-Federal entities must establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. During fiscal year 2024, the District participated in Child Nutrition Cluster programs, for which the federal government reimburses the District for eligible children. During the school year, the School District is required to establish a child's eligibility to receive program benefits. The District accepted online applications for free and reduced meals, with which eligibility was determined based on several factors, including, but not limited to family size and income. For fiscal year 2024, the eligibility process was 100% online through PaySchools to determine eligibility for free and reduced meals. The option selected within PaySchools by the District was for the portal applications uploaded from RocketScan to be approved as entered (if the eligibility criteria was met) with no additional review, rather than applications being in pending status until reviewed and approved by the District. As such, the District had no procedures in place to ensure the system determined the proper eligibility status based on the information provided in the application. Failure to implement controls over all eligibility applications could result in ineligible students receiving benefits. The District should implement control procedures for online applications to help ensure students are properly marked as paid, free or reduced.
Finding Number: 2024‐001 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Housing Voucher Cluster 14.871 N/A N/A Coronavirus State and Local Fiscal Recovery Fund 21.207 N/A N/A Federal Agency(ies): Department of Housing and Urban Development, Department of Treasury Pass‐Through Agency(ies): Direct, Arizona Governor’s Office Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Reporting Criteria Under 2 CFR §200.303, the City is required to establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the City is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, PHAs submit HUD‐52681‐B monthly to HUD electronically via the VMS. Critical information from this report including unit months leased, HAP expenses, unrestricted net position (administrative fee reserves), restricted net position (HAP reserves), and cash in investments should be accurate and supported. In addition, recipients of Coronavirus Local Fiscal Recovery Fund monies are required to submit Project and Expenditure Reports either quarterly or annually in accordance with the SLFRF Compliance and Reporting Guidance issued by the Department of Treasury. In addition, in accordance with 2 CFR §200.512, the single audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Condition The City did not have consistent processes and procedures to track federal grant information and expenditures. In addition, adequate supporting documentation for amounts reported was not maintained and the single audit was not submitted timely. Cause The City's internal controls were not adequately designed to track federal grant information needed for the Schedule of Expenditures of Federal Awards (SEFA). In addition, controls over document retention and report submission did not function as designed. Effect The City was not in compliance with federal regulations and guidelines for reporting. Context The following items were noted: The City does not have a consistent process to track federal grant information and expenditures. As a result, $113,998 of Coronavirus Local Fiscal Recovery Fund expenditures were not reported on the fiscal year 2023 SEFA. For all three Housing Voucher Cluster monthly financial reports reviewed, the City could not support how unrestricted net position and restricted net position agreed to the financial reporting software. The annual Project and Expenditures Report for the Coronavirus State and Local Fiscal Recovery Funds program did not have accurately reported obligation or expenditures amounts. The City's Single Audit Report was not completed and submitted within nine months of fiscal year‐end. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The City should standardize its process for tracking federal grant information, including the expenditure amount necessary for SEFA reporting. The City should design and implement effective internal controls over the review and retention of supporting documentation regarding the amounts reported. In addition, the City should implement better controls over financial reporting to ensure all documents are prepared and available for the timely completion of the financial and single audit reports. Views of Responsible Officials See Corrective Action Plan.
Finding Number: 2024‐001 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Housing Voucher Cluster 14.871 N/A N/A Coronavirus State and Local Fiscal Recovery Fund 21.207 N/A N/A Federal Agency(ies): Department of Housing and Urban Development, Department of Treasury Pass‐Through Agency(ies): Direct, Arizona Governor’s Office Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Reporting Criteria Under 2 CFR §200.303, the City is required to establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the City is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, PHAs submit HUD‐52681‐B monthly to HUD electronically via the VMS. Critical information from this report including unit months leased, HAP expenses, unrestricted net position (administrative fee reserves), restricted net position (HAP reserves), and cash in investments should be accurate and supported. In addition, recipients of Coronavirus Local Fiscal Recovery Fund monies are required to submit Project and Expenditure Reports either quarterly or annually in accordance with the SLFRF Compliance and Reporting Guidance issued by the Department of Treasury. In addition, in accordance with 2 CFR §200.512, the single audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Condition The City did not have consistent processes and procedures to track federal grant information and expenditures. In addition, adequate supporting documentation for amounts reported was not maintained and the single audit was not submitted timely. Cause The City's internal controls were not adequately designed to track federal grant information needed for the Schedule of Expenditures of Federal Awards (SEFA). In addition, controls over document retention and report submission did not function as designed. Effect The City was not in compliance with federal regulations and guidelines for reporting. Context The following items were noted: The City does not have a consistent process to track federal grant information and expenditures. As a result, $113,998 of Coronavirus Local Fiscal Recovery Fund expenditures were not reported on the fiscal year 2023 SEFA. For all three Housing Voucher Cluster monthly financial reports reviewed, the City could not support how unrestricted net position and restricted net position agreed to the financial reporting software. The annual Project and Expenditures Report for the Coronavirus State and Local Fiscal Recovery Funds program did not have accurately reported obligation or expenditures amounts. The City's Single Audit Report was not completed and submitted within nine months of fiscal year‐end. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The City should standardize its process for tracking federal grant information, including the expenditure amount necessary for SEFA reporting. The City should design and implement effective internal controls over the review and retention of supporting documentation regarding the amounts reported. In addition, the City should implement better controls over financial reporting to ensure all documents are prepared and available for the timely completion of the financial and single audit reports. Views of Responsible Officials See Corrective Action Plan.
Finding Number: 2024‐001 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Housing Voucher Cluster 14.871 N/A N/A Coronavirus State and Local Fiscal Recovery Fund 21.207 N/A N/A Federal Agency(ies): Department of Housing and Urban Development, Department of Treasury Pass‐Through Agency(ies): Direct, Arizona Governor’s Office Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Reporting Criteria Under 2 CFR §200.303, the City is required to establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the City is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, PHAs submit HUD‐52681‐B monthly to HUD electronically via the VMS. Critical information from this report including unit months leased, HAP expenses, unrestricted net position (administrative fee reserves), restricted net position (HAP reserves), and cash in investments should be accurate and supported. In addition, recipients of Coronavirus Local Fiscal Recovery Fund monies are required to submit Project and Expenditure Reports either quarterly or annually in accordance with the SLFRF Compliance and Reporting Guidance issued by the Department of Treasury. In addition, in accordance with 2 CFR §200.512, the single audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Condition The City did not have consistent processes and procedures to track federal grant information and expenditures. In addition, adequate supporting documentation for amounts reported was not maintained and the single audit was not submitted timely. Cause The City's internal controls were not adequately designed to track federal grant information needed for the Schedule of Expenditures of Federal Awards (SEFA). In addition, controls over document retention and report submission did not function as designed. Effect The City was not in compliance with federal regulations and guidelines for reporting. Context The following items were noted: The City does not have a consistent process to track federal grant information and expenditures. As a result, $113,998 of Coronavirus Local Fiscal Recovery Fund expenditures were not reported on the fiscal year 2023 SEFA. For all three Housing Voucher Cluster monthly financial reports reviewed, the City could not support how unrestricted net position and restricted net position agreed to the financial reporting software. The annual Project and Expenditures Report for the Coronavirus State and Local Fiscal Recovery Funds program did not have accurately reported obligation or expenditures amounts. The City's Single Audit Report was not completed and submitted within nine months of fiscal year‐end. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The City should standardize its process for tracking federal grant information, including the expenditure amount necessary for SEFA reporting. The City should design and implement effective internal controls over the review and retention of supporting documentation regarding the amounts reported. In addition, the City should implement better controls over financial reporting to ensure all documents are prepared and available for the timely completion of the financial and single audit reports. Views of Responsible Officials See Corrective Action Plan.
Condition: An effective internal control system was not in place to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Criteria: 2 CFR section 200.303 states in part: "The Non-Federal entity must: Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal 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)." Cause: CICOA's management did not maintain a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: Several required reports were not submitted timely to the Indiana Family and Social Services Administration in accordance with its grant awards. The following reports were identified as not being completed and submitted timely: The expenditure data is to be entered within 75 days of the quarter. From a sample size of four, the December 31, 2023, and the June 30, 2024, reports were not fully completed and submitted within the 75-day requirement. The non-federal expenditures report is to be submitted within 15 days after the end of the quarter. None of the quarterly reports were filed until November 19, 2024. Recommendation: We recommend that CICOA establish controls to ensure proper monitoring exists to ensure all reporting requirements for the grants are prepared and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management recognizes its compliance requirements for maintaining and implementing sound controls over financial reporting and the potential non-compliance impacts of a lack of such control environment. Steps have been taken and implemented on January 1, 2025 to ensure adequate oversight and review takes place. All reporting requirements and due dates are currently being submitted timely.
Condition: An effective internal control system was not in place to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Criteria: 2 CFR section 200.303 states in part: "The Non-Federal entity must: Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal 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)." Cause: CICOA's management did not maintain a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: Several required reports were not submitted timely to the Indiana Family and Social Services Administration in accordance with its grant awards. The following reports were identified as not being completed and submitted timely: The expenditure data is to be entered within 75 days of the quarter. From a sample size of four, the December 31, 2023, and the June 30, 2024, reports were not fully completed and submitted within the 75-day requirement. The non-federal expenditures report is to be submitted within 15 days after the end of the quarter. None of the quarterly reports were filed until November 19, 2024. Recommendation: We recommend that CICOA establish controls to ensure proper monitoring exists to ensure all reporting requirements for the grants are prepared and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management recognizes its compliance requirements for maintaining and implementing sound controls over financial reporting and the potential non-compliance impacts of a lack of such control environment. Steps have been taken and implemented on January 1, 2025 to ensure adequate oversight and review takes place. All reporting requirements and due dates are currently being submitted timely.
Condition: An effective internal control system was not in place to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Criteria: 2 CFR section 200.303 states in part: "The Non-Federal entity must: Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal 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)." Cause: CICOA's management did not maintain a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: Several required reports were not submitted timely to the Indiana Family and Social Services Administration in accordance with its grant awards. The following reports were identified as not being completed and submitted timely: The expenditure data is to be entered within 75 days of the quarter. From a sample size of four, the December 31, 2023, and the June 30, 2024, reports were not fully completed and submitted within the 75-day requirement. The non-federal expenditures report is to be submitted within 15 days after the end of the quarter. None of the quarterly reports were filed until November 19, 2024. Recommendation: We recommend that CICOA establish controls to ensure proper monitoring exists to ensure all reporting requirements for the grants are prepared and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management recognizes its compliance requirements for maintaining and implementing sound controls over financial reporting and the potential non-compliance impacts of a lack of such control environment. Steps have been taken and implemented on January 1, 2025 to ensure adequate oversight and review takes place. All reporting requirements and due dates are currently being submitted timely.
Condition: An effective internal control system was not in place to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Criteria: 2 CFR section 200.303 states in part: "The Non-Federal entity must: Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal 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)." Cause: CICOA's management did not maintain a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: Several required reports were not submitted timely to the Indiana Family and Social Services Administration in accordance with its grant awards. The following reports were identified as not being completed and submitted timely: The expenditure data is to be entered within 75 days of the quarter. From a sample size of four, the December 31, 2023, and the June 30, 2024, reports were not fully completed and submitted within the 75-day requirement. The non-federal expenditures report is to be submitted within 15 days after the end of the quarter. None of the quarterly reports were filed until November 19, 2024. Recommendation: We recommend that CICOA establish controls to ensure proper monitoring exists to ensure all reporting requirements for the grants are prepared and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management recognizes its compliance requirements for maintaining and implementing sound controls over financial reporting and the potential non-compliance impacts of a lack of such control environment. Steps have been taken and implemented on January 1, 2025 to ensure adequate oversight and review takes place. All reporting requirements and due dates are currently being submitted timely.
Condition: An effective internal control system was not in place to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Criteria: 2 CFR section 200.303 states in part: "The Non-Federal entity must: Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal 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)." Cause: CICOA's management did not maintain a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: Several required reports were not submitted timely to the Indiana Family and Social Services Administration in accordance with its grant awards. The following reports were identified as not being completed and submitted timely: The expenditure data is to be entered within 75 days of the quarter. From a sample size of four, the December 31, 2023, and the June 30, 2024, reports were not fully completed and submitted within the 75-day requirement. The non-federal expenditures report is to be submitted within 15 days after the end of the quarter. None of the quarterly reports were filed until November 19, 2024. Recommendation: We recommend that CICOA establish controls to ensure proper monitoring exists to ensure all reporting requirements for the grants are prepared and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management recognizes its compliance requirements for maintaining and implementing sound controls over financial reporting and the potential non-compliance impacts of a lack of such control environment. Steps have been taken and implemented on January 1, 2025 to ensure adequate oversight and review takes place. All reporting requirements and due dates are currently being submitted timely.
Condition: An effective internal control system was not in place to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Criteria: 2 CFR section 200.303 states in part: "The Non-Federal entity must: Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal 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)." Cause: CICOA's management did not maintain a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: Several required reports were not submitted timely to the Indiana Family and Social Services Administration in accordance with its grant awards. The following reports were identified as not being completed and submitted timely: The expenditure data is to be entered within 75 days of the quarter. From a sample size of four, the December 31, 2023, and the June 30, 2024, reports were not fully completed and submitted within the 75-day requirement. The non-federal expenditures report is to be submitted within 15 days after the end of the quarter. None of the quarterly reports were filed until November 19, 2024. Recommendation: We recommend that CICOA establish controls to ensure proper monitoring exists to ensure all reporting requirements for the grants are prepared and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management recognizes its compliance requirements for maintaining and implementing sound controls over financial reporting and the potential non-compliance impacts of a lack of such control environment. Steps have been taken and implemented on January 1, 2025 to ensure adequate oversight and review takes place. All reporting requirements and due dates are currently being submitted timely.
Condition: An effective internal control system was not in place to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Criteria: 2 CFR section 200.303 states in part: "The Non-Federal entity must: Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal 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)." Cause: CICOA's management did not maintain a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: Several required reports were not submitted timely to the Indiana Family and Social Services Administration in accordance with its grant awards. The following reports were identified as not being completed and submitted timely: The expenditure data is to be entered within 75 days of the quarter. From a sample size of four, the December 31, 2023, and the June 30, 2024, reports were not fully completed and submitted within the 75-day requirement. The non-federal expenditures report is to be submitted within 15 days after the end of the quarter. None of the quarterly reports were filed until November 19, 2024. Recommendation: We recommend that CICOA establish controls to ensure proper monitoring exists to ensure all reporting requirements for the grants are prepared and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management recognizes its compliance requirements for maintaining and implementing sound controls over financial reporting and the potential non-compliance impacts of a lack of such control environment. Steps have been taken and implemented on January 1, 2025 to ensure adequate oversight and review takes place. All reporting requirements and due dates are currently being submitted timely.
Condition: An effective internal control system was not in place to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Criteria: 2 CFR section 200.303 states in part: "The Non-Federal entity must: Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal 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)." Cause: CICOA's management did not maintain a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: Several required reports were not submitted timely to the Indiana Family and Social Services Administration in accordance with its grant awards. The following reports were identified as not being completed and submitted timely: The expenditure data is to be entered within 75 days of the quarter. From a sample size of four, the December 31, 2023, and the June 30, 2024, reports were not fully completed and submitted within the 75-day requirement. The non-federal expenditures report is to be submitted within 15 days after the end of the quarter. None of the quarterly reports were filed until November 19, 2024. Recommendation: We recommend that CICOA establish controls to ensure proper monitoring exists to ensure all reporting requirements for the grants are prepared and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management recognizes its compliance requirements for maintaining and implementing sound controls over financial reporting and the potential non-compliance impacts of a lack of such control environment. Steps have been taken and implemented on January 1, 2025 to ensure adequate oversight and review takes place. All reporting requirements and due dates are currently being submitted timely.
Condition: An effective internal control system was not in place to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Criteria: 2 CFR section 200.303 states in part: "The Non-Federal entity must: Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal 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)." Cause: CICOA's management did not maintain a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: Several required reports were not submitted timely to the Indiana Family and Social Services Administration in accordance with its grant awards. The following reports were identified as not being completed and submitted timely: The expenditure data is to be entered within 75 days of the quarter. From a sample size of four, the December 31, 2023, and the June 30, 2024, reports were not fully completed and submitted within the 75-day requirement. The non-federal expenditures report is to be submitted within 15 days after the end of the quarter. None of the quarterly reports were filed until November 19, 2024. Recommendation: We recommend that CICOA establish controls to ensure proper monitoring exists to ensure all reporting requirements for the grants are prepared and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management recognizes its compliance requirements for maintaining and implementing sound controls over financial reporting and the potential non-compliance impacts of a lack of such control environment. Steps have been taken and implemented on January 1, 2025 to ensure adequate oversight and review takes place. All reporting requirements and due dates are currently being submitted timely.
Condition: An effective internal control system was not in place to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Criteria: 2 CFR section 200.303 states in part: "The Non-Federal entity must: Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal 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)." Cause: CICOA's management did not maintain a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: Several required reports were not submitted timely to the Indiana Family and Social Services Administration in accordance with its grant awards. The following reports were identified as not being completed and submitted timely: The expenditure data is to be entered within 75 days of the quarter. From a sample size of four, the December 31, 2023, and the June 30, 2024, reports were not fully completed and submitted within the 75-day requirement. The non-federal expenditures report is to be submitted within 15 days after the end of the quarter. None of the quarterly reports were filed until November 19, 2024. Recommendation: We recommend that CICOA establish controls to ensure proper monitoring exists to ensure all reporting requirements for the grants are prepared and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management recognizes its compliance requirements for maintaining and implementing sound controls over financial reporting and the potential non-compliance impacts of a lack of such control environment. Steps have been taken and implemented on January 1, 2025 to ensure adequate oversight and review takes place. All reporting requirements and due dates are currently being submitted timely.
Condition: An effective internal control system was not in place to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Criteria: 2 CFR section 200.303 states in part: "The Non-Federal entity must: Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal 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)." Cause: CICOA's management did not maintain a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: Several required reports were not submitted timely to the Indiana Family and Social Services Administration in accordance with its grant awards. The following reports were identified as not being completed and submitted timely: The expenditure data is to be entered within 75 days of the quarter. From a sample size of four, the December 31, 2023, and the June 30, 2024, reports were not fully completed and submitted within the 75-day requirement. The non-federal expenditures report is to be submitted within 15 days after the end of the quarter. None of the quarterly reports were filed until November 19, 2024. Recommendation: We recommend that CICOA establish controls to ensure proper monitoring exists to ensure all reporting requirements for the grants are prepared and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management recognizes its compliance requirements for maintaining and implementing sound controls over financial reporting and the potential non-compliance impacts of a lack of such control environment. Steps have been taken and implemented on January 1, 2025 to ensure adequate oversight and review takes place. All reporting requirements and due dates are currently being submitted timely.
2024-003 United States Department Agriculture Federal Financial Assistance Listing #10.766 Community Facilities Loans and Grant Special Tests and Provisions Significant Deficiency in Internal Control Over Compliance 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 – During our testing, there was no formal review separate from the preparer over the reserve fund reconciliation for the federal program and there was no formal review of the balance in comparison to the required minimum reserve balance. Cause – The Health Center did not have an adequate internal control policy in place to ensure review and approval over the amount of the reserve fund. Effect – The lack of adequate policies governing review increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs – None reported. Context – Sampling was not used. The Health Center has one reserve account, which includes the debt service and emergency and replacement reserve, that was tested. Repeat Finding from Prior Years – Yes, Finding 2023-004 Recommendation – We recommend that the Health Center enhance internal control policies to ensure that a formal review over the reserve fund reconciliation and a formal review of the balance in comparison to the required minimum reserve balance be completed by staff separate from the preparer. Views of Responsible Officials – Management agrees with the finding.
Program - AL 21.027 - COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment Grant Number & Year - SLFRP1468; March 3, 2021, through December 31, 2024 Federal Grantor Agency - U.S. Department of the Treasury Criteria - Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2024) states the following, in relevant part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2024), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. 2 CFR § 200.214 (January 1, 2024) states the following: Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR § 180.300 (January 1, 2024) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by: “(a) Checking SAM Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . . [entity].” A good internal control plan requires the County to have proper procedures in place to verify that vendors paid with Federal funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities. Condition - The County could not provide documentation to support that the County implementedeffective internal controls to ensure that suspension and debarment requirements were followed and adequately documented. We noted the County used Coronavirus State and Local Fiscal Recovery Funds to pay two vendors over $25,000, totaling $548,036 during the fiscal year ended June 30, 2024. The County failed to ensure that these vendors were not excluded or disqualified prior to entering into these covered transactions. We reviewed sam.gov and noted that none of these vendors were suspended, debarred, or otherwise excluded from participation in Federal programs or activities as of the date testing was performed. Repeat Finding - No Questioned Costs - None Statistical Sample - No Context - The following table provides details of the covered transactions noted: Cause - Lack of procedures and knowledge regarding suspension and debarment requirements. Effect - Without adequate procedures to ensure vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions. Recommendation - We recommend the County implement procedures to ensure, prior to entering into acovered transaction, that a vendor is not suspended, debarred, or otherwise excluded fromor ineligible for participation in Federal programs or activities, and those procedures areadequately documented. View of Officials - The County will implement procedures to ensure when a contractor is paid with federal funds, sam.gov will be utilized to verify the entity has not been suspended or debarred and such procedure will be adequately documented.
Finding 2024-001: Untimely and Inaccurate Enrollment Reporting Compliance Requirement: Special Tests & Provisions: Enrollment Reporting Type: Material Weakness in Internal Control over Compliance; Material Noncompliance Federal Awarding Agency: U.S. Department of Education AL Numbers and Titles: 84.063 and 84.268 – Student Financial Aid Cluster Grant Award Period: July 1, 2023 through June 30, 2024 Questioned Costs: None Repeat Finding: No Criteria: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing of 12 students, we identified 9 students for which the student's enrollment status was not reported timely to the National Student Loan Data System (NSLDS) and 8 students whose graduation status was not accurately reported to the NSLDS. Cause: During the year, the University submitted its listing of individuals who graduated to Clearinghouse to upload to NSLDS. However, the University did not review the listing of exceptions from Clearinghouse related to the students whose status changes were not uploaded to NSLDS, which caused the enrollment changes for students who graduated to not be reported in accordance with federal requirements. This caused students to not be reported to NSLDS until the audit.Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of Responsible Officials Corrective Actions: The University agrees with this finding. Please refer to the Corrective Action Plan.
Finding 2024-001: Untimely and Inaccurate Enrollment Reporting Compliance Requirement: Special Tests & Provisions: Enrollment Reporting Type: Material Weakness in Internal Control over Compliance; Material Noncompliance Federal Awarding Agency: U.S. Department of Education AL Numbers and Titles: 84.063 and 84.268 – Student Financial Aid Cluster Grant Award Period: July 1, 2023 through June 30, 2024 Questioned Costs: None Repeat Finding: No Criteria: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing of 12 students, we identified 9 students for which the student's enrollment status was not reported timely to the National Student Loan Data System (NSLDS) and 8 students whose graduation status was not accurately reported to the NSLDS. Cause: During the year, the University submitted its listing of individuals who graduated to Clearinghouse to upload to NSLDS. However, the University did not review the listing of exceptions from Clearinghouse related to the students whose status changes were not uploaded to NSLDS, which caused the enrollment changes for students who graduated to not be reported in accordance with federal requirements. This caused students to not be reported to NSLDS until the audit.Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of Responsible Officials Corrective Actions: The University agrees with this finding. Please refer to the Corrective Action Plan.
2024-003 Department of Agriculture Federal Assistance Listing #10.766 Community Facilities Loans and Grants Cluster Special Tests and Provisions Significant Deficiency in Internal Control over Compliance Criteria - 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal awards. Condition - During our testing, there was no formal review separate from the preparer over the reserve fund reconciliations for the federal program. Cause - The Home did not have an adequate internal control policy in place to ensure review and approval over the reserve fund reconciliations. Effect - The lack of adequate policies governing review increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs - None reported. Context/Sampling - Sampling was not used. The Home has two required reserve fund requirements that were tested. Repeat Finding from Prior Years - Yes - 2023-004 Recommendation - We recommend that the Home enhance internal control policies to ensure that formal documentation of reviews is present. Views of Responsible Officials - Management agrees with the finding.
Finding # 2024-002 Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment Grant Number & Year: SLFRP0847, March 3, 2021, through December 31, 2024 Federal Grantor Agency: U.S. Department of the Treasury Criteria: Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2024) states the following, in relevant part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR § 200.214 (January 1, 2024) states the following: Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2024), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. 2 CFR § 180.300 (January 1, 2024) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by “(a) Checking SAM Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . . [entity].” A good internal control plan requires the County to have proper procedures in place to verify that contractors paid with Federal funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. Condition: Dawson County could not provide documentation to support that the County implemented effective internal controls to ensure that suspension and debarment requirements were followed and adequately documented. We noted the County used Coronavirus State and Local Fiscal Recovery Funds to pay 12 vendors over $25,000 each, totaling $2,875,367, during the fiscal year ended June 30, 2024. The County was unable to support that a review was performed to ensure that these vendors were not excluded or disqualified prior to entering into these covered transactions. We reviewed SAM.gov, and noted that none of these vendors were suspended, debarred, or otherwise excluded from participation in Federal programs or activities as of the date testing was performed. Repeat Finding: 2023-002 Questioned Costs: None Statistical Sample: No Context: The following table provides details of the covered transactions noted: Cause: Lack of procedures and knowledge regarding suspension and debarment requirements; long-time County Clerk retired during the fiscal year. Effect: Without adequate procedures to ensure contractors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions. Recommendation: We recommend the County implement procedures to ensure, prior to entering into a covered transaction, that a contractor is not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. View of Officials: The County has procedures in place; when a contractor is hired, sam.gov will be utilized to verify the entity has not been suspended or debarred.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
2024 – 001: Improper Payroll Calculation Federal Agency: U.S. Department of Energy Federal Program Name: Research & Development Cluster Assistance Listing Number: 81.049 Federal Award Identification Number: DE-SC0023385 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – Per 2 CFR § 200.403, except where otherwise authorized by statute, costs must meet the following general criteria to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award to be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award regarding types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally‐financed and other activities of the non‐Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally‐financed program in either the current or a prior period. (g) Be adequately documented. Condition: The University incorrectly calculated payroll costs charged to the grant after an employee was double paid for the same work hours. Questioned costs: $400. Context: This condition occurred for 1 out of 40 payroll costs selected for testing resulting in $400 being incorrectly charged to the program. Cause: An employee failed to accurately enter time worked into the university timekeeping system for the pay period 5/1/24 – 5/15/24. The employee reported the hours to their department contact on 5/29/24, which was after the pay period had closed and paychecks had already been processed. The department liaison contacted Kronos Support to have the hours added to the timecard retroactively. Kronos Support received confirmation from the employee that the missed hours could be added to the paycheck for 6/14/24. During payroll processing for 6/14/24, Kronos Support added the missed hours to the employee’s payline on 6/5/24. The department liaison also submitted a CU Special Pay for the same missed hours on 6/5/24. Due to the timing of each separate transaction, Kronos Support did not have visibility into the duplication of the hours. The department failed to identify the duplication during its review of payroll reports. Effect: Expenditures may be incorrectly charged to the program. Repeat Finding: No Recommendation: We recommend that the institution strengthen its internal controls to ensure that expenditures are reviewed and adjusted for, if necessary, in a timely manner. Views of responsible officials: Management acknowledges the finding.
2024 – 002: Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis response Assistance Listing Number: 93.354 Federal Award Identification Number: NU90TP922168, NU90TP921992 Pass-Through Agency: South Carolina Department of Health and Environmental Control Pass-Through Numbers: PH-2-533, CY-19-018 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance - Per 2 CFR section 200.332(a), the subaward is to clearly identify to the subrecipient required information, including identification of whether the award is R&D. Condition: The University incorrectly documented the subaward as a Research and Development grant to the subrecipient. Questioned costs: None Context: This condition occurred for 5 out of 5 subawards selected for testing. Cause: Attachment 2 of the Federal Awards Terms and Conditions template of the FDP Cost Reimbursement Subaward includes a field that is pre-selected and defaults to the R&D selection, requiring the field to be unchecked for the subawards that are not classified as R&D. Effect: The subrecipient may not be aware of certain award information in order to comply with federal statutes, regulations, and the terms and conditions of the award and properly classify its schedule of expenditures of federal awards. Repeat Finding: No Recommendation: We recommend the University strengthen its internal controls to ensure that subawards report the correct information. Views of responsible officials: Management acknowledges the finding.
2024 – 002: Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis response Assistance Listing Number: 93.354 Federal Award Identification Number: NU90TP922168, NU90TP921992 Pass-Through Agency: South Carolina Department of Health and Environmental Control Pass-Through Numbers: PH-2-533, CY-19-018 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance - Per 2 CFR section 200.332(a), the subaward is to clearly identify to the subrecipient required information, including identification of whether the award is R&D. Condition: The University incorrectly documented the subaward as a Research and Development grant to the subrecipient. Questioned costs: None Context: This condition occurred for 5 out of 5 subawards selected for testing. Cause: Attachment 2 of the Federal Awards Terms and Conditions template of the FDP Cost Reimbursement Subaward includes a field that is pre-selected and defaults to the R&D selection, requiring the field to be unchecked for the subawards that are not classified as R&D. Effect: The subrecipient may not be aware of certain award information in order to comply with federal statutes, regulations, and the terms and conditions of the award and properly classify its schedule of expenditures of federal awards. Repeat Finding: No Recommendation: We recommend the University strengthen its internal controls to ensure that subawards report the correct information. Views of responsible officials: Management acknowledges the finding.
Criteria or Specific Requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62) The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: The College under-awarded funds for the Pell Grant. Questioned Costs: None. Context: During our testing we noted one of forty students, from a statistically valid sample, were disbursed awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Cause: The College did not award the correct amount of the Pell grant due to the lack of a manual adjustment that was needed for this instance. Effect: Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has developed a plan to correct it.