Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: Not Provided Pass-Through Agency: Maryland State Department of Education Pass-Through Number: Not Available Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Control: According to the Carroll County Board of Education's procurement policy, any contract valued at over $25,000 must obtain board approval. This ensures compliance with internal controls and procurement regulations as specified in their policy manual and 2 CFR section 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. Condition/Context: For one of seven vendors selected for testing, the Carroll County Board of Education failed to obtain board approval for a contract valued at over $25,000, as required by their procurement policy. Questioned Costs: None Noted. Cause: The Board did not adhere to its established procedures for obtaining necessary approvals for this contract exceeding $25,000 because the initial purchase was intended to be below the approval threshold. However, the total value of the contract was not fully considered. Effect: Failure to comply with the board approval requirement may result in unauthorized procurement activities and potential mismanagement of federal funds. Repeat Finding: No Recommendation: We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: Not Provided Pass-Through Agency: Maryland State Department of Education Pass-Through Number: Not Available Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Control: According to the Carroll County Board of Education's procurement policy, any contract valued at over $25,000 must obtain board approval. This ensures compliance with internal controls and procurement regulations as specified in their policy manual and 2 CFR section 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. Condition/Context: For one of seven vendors selected for testing, the Carroll County Board of Education failed to obtain board approval for a contract valued at over $25,000, as required by their procurement policy. Questioned Costs: None Noted. Cause: The Board did not adhere to its established procedures for obtaining necessary approvals for this contract exceeding $25,000 because the initial purchase was intended to be below the approval threshold. However, the total value of the contract was not fully considered. Effect: Failure to comply with the board approval requirement may result in unauthorized procurement activities and potential mismanagement of federal funds. Repeat Finding: No Recommendation: We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: Not Provided Pass-Through Agency: Maryland State Department of Education Pass-Through Number: Not Available Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Control: According to the Carroll County Board of Education's procurement policy, any contract valued at over $25,000 must obtain board approval. This ensures compliance with internal controls and procurement regulations as specified in their policy manual and 2 CFR section 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. Condition/Context: For one of seven vendors selected for testing, the Carroll County Board of Education failed to obtain board approval for a contract valued at over $25,000, as required by their procurement policy. Questioned Costs: None Noted. Cause: The Board did not adhere to its established procedures for obtaining necessary approvals for this contract exceeding $25,000 because the initial purchase was intended to be below the approval threshold. However, the total value of the contract was not fully considered. Effect: Failure to comply with the board approval requirement may result in unauthorized procurement activities and potential mismanagement of federal funds. Repeat Finding: No Recommendation: We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: Not Provided Pass-Through Agency: Maryland State Department of Education Pass-Through Number: Not Available Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Control: According to the Carroll County Board of Education's procurement policy, any contract valued at over $25,000 must obtain board approval. This ensures compliance with internal controls and procurement regulations as specified in their policy manual and 2 CFR section 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. Condition/Context: For one of seven vendors selected for testing, the Carroll County Board of Education failed to obtain board approval for a contract valued at over $25,000, as required by their procurement policy. Questioned Costs: None Noted. Cause: The Board did not adhere to its established procedures for obtaining necessary approvals for this contract exceeding $25,000 because the initial purchase was intended to be below the approval threshold. However, the total value of the contract was not fully considered. Effect: Failure to comply with the board approval requirement may result in unauthorized procurement activities and potential mismanagement of federal funds. Repeat Finding: No Recommendation: We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: Not Provided Pass-Through Agency: Maryland State Department of Education Pass-Through Number: Not Available Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Control: According to the Carroll County Board of Education's procurement policy, any contract valued at over $25,000 must obtain board approval. This ensures compliance with internal controls and procurement regulations as specified in their policy manual and 2 CFR section 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. Condition/Context: For one of seven vendors selected for testing, the Carroll County Board of Education failed to obtain board approval for a contract valued at over $25,000, as required by their procurement policy. Questioned Costs: None Noted. Cause: The Board did not adhere to its established procedures for obtaining necessary approvals for this contract exceeding $25,000 because the initial purchase was intended to be below the approval threshold. However, the total value of the contract was not fully considered. Effect: Failure to comply with the board approval requirement may result in unauthorized procurement activities and potential mismanagement of federal funds. Repeat Finding: No Recommendation: We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: Not Provided Pass-Through Agency: Maryland State Department of Education Pass-Through Number: Not Available Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Control: According to the Carroll County Board of Education's procurement policy, any contract valued at over $25,000 must obtain board approval. This ensures compliance with internal controls and procurement regulations as specified in their policy manual and 2 CFR section 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. Condition/Context: For one of seven vendors selected for testing, the Carroll County Board of Education failed to obtain board approval for a contract valued at over $25,000, as required by their procurement policy. Questioned Costs: None Noted. Cause: The Board did not adhere to its established procedures for obtaining necessary approvals for this contract exceeding $25,000 because the initial purchase was intended to be below the approval threshold. However, the total value of the contract was not fully considered. Effect: Failure to comply with the board approval requirement may result in unauthorized procurement activities and potential mismanagement of federal funds. Repeat Finding: No Recommendation: We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: Not Provided Pass-Through Agency: Maryland State Department of Education Pass-Through Number: Not Available Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Control: According to the Carroll County Board of Education's procurement policy, any contract valued at over $25,000 must obtain board approval. This ensures compliance with internal controls and procurement regulations as specified in their policy manual and 2 CFR section 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. Condition/Context: For one of seven vendors selected for testing, the Carroll County Board of Education failed to obtain board approval for a contract valued at over $25,000, as required by their procurement policy. Questioned Costs: None Noted. Cause: The Board did not adhere to its established procedures for obtaining necessary approvals for this contract exceeding $25,000 because the initial purchase was intended to be below the approval threshold. However, the total value of the contract was not fully considered. Effect: Failure to comply with the board approval requirement may result in unauthorized procurement activities and potential mismanagement of federal funds. Repeat Finding: No Recommendation: We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Views of responsible officials: There is no disagreement with the finding.
Assistance Listing Number, Federal Agency, and Program Name - ALN 97.036, Department of Homeland Security, Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) Federal Award Identification Number and Year - PA-05-MI-4607-PW-00098(0) Pass-through Entity - Michigan State Police Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The FEMA grant expenses are charged to various funds in the general ledger over several years but is managed and tracked by project in a manual spreadsheet that agrees to the amount of expenses reported on the fiscal year 2024 schedule of expenditures of federal awards (the "Schedule"). FEMA expenditures are reported on the Schedule when there is an award and expenditures. Given that the award is made subsequent to the expenditures being incurred, a manual spreadsheet is used to track expenditures being charged to the grant. There were instances of duplicated costs in the manual spreadsheet. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The FEMA projects have periods of performances that began prior to fiscal year 2024. As a result, the City used spreadsheets to accumulate costs to charge to the projects. Given that manual processes carry a higher risk of error due to their reliance on human input, in addition to our allowability sample, we performed an analysis of the spreadsheet, which listed all costs charged to the grant during fiscal year 2024, and found 11 instances of duplicate costs totaling $5,161. Of the $5,161 submitted, FEMA reimburses ninety percent of the amount, i.e., $4,645. Cause and Effect - A lack of effective controls over the spreadsheet did not identify $5,161 of duplicative costs. The schedule of expenditures of federal awards was initially overstated by this amount. These costs have been excluded from the Schedule for the year ended June 30, 2024. Recommendation - We recommend the City continue to evaluate its processes and controls when manual processes are utilized to accumulate costs charged to a grant, including risk assessing for gaps that can cause noncompliance. Based on the gaps identified, we recommend the City implement effective controls to address the risks. Views of Responsible Officials and Corrective Action Plan - Detroit Water and Sewer Department (DWSD) management recognizes the importance of maintaining effective controls to ensure the accuracy and completeness of reported expenditures. The identified duplicate cost was an isolated occurrence caused by an oversight during the spreadsheet preparation process. While existing controls are in place, management will perform a secondary review of the end to end process to enhance these controls.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the 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 City is required to complete inspections of HOME assisted units to ensure they meet the HUD housing standards as outlined in 24 CFR 92.251(b) (viii). During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing 1 to 4 units, (b) every two years for projects containing 5 to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on site inspections of rental housing occupied by tenants receiving HOME/HOME ARP assisted tenant based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). Per the City’s Home Program manual adopted on July 1, 2022, at least 20 percent of the HOME assisted units must be rented to households at or below 50 percent of the area median income. The City is required to perform the inspections under the housing quality standards for these units. Condition - The City’s on site inspections for compliance with the housing quality standards are triggered by the City’s process to audit developers for compliance with HOME eligibility requirements. This basis is more restrictive than federal requirements for housing quality inspections. At the end of an inspection cycle, a certificate of completion is completed and signed by the responsible inspector. The City did not have effective controls to ensure the certificate of completion is reviewed for completeness and accuracy. The City did not inspect 20 percent of the units, as required by its policy. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In the process of understanding the controls over compliance with housing quality standards requirement, we noted that the certificate of completion, which is completed at the end of an inspection cycle, was not consistently reviewed. In addition, in one out the three projects selected for testing for compliance with the housing quality standards, the City did not inspect 20 percent of the units at the property, as outlined in their Home Program manual. Cause and Effect - The controls in place to ensure the certificate of completion is reviewed for completeness and accuracy, including review to ensure 20 percent of the units are inspected, were not in place. The lack of controls resulted in a project not having adequate units reviewed. Furthermore, the lack of controls could result in an instance of noncompliance not being identified. Recommendation - We recommend the City ensure controls are in place to comply with the Home Program manual and federal regulations related to housing quality standards. Views of Responsible Officials and Planned Corrective Actions - The City will review its processes and implement additional controls to ensure certificates of completion are reviewed for completeness and accuracy and to verify 20 percent of the units are inspected to comply with the HOME Program manual and federal regulations related to housing quality standards.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the 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 City is required to complete inspections of HOME assisted units to ensure they meet the HUD housing standards as outlined in 24 CFR 92.251(b) (viii). During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing 1 to 4 units, (b) every two years for projects containing 5 to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on site inspections of rental housing occupied by tenants receiving HOME/HOME ARP assisted tenant based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). Per the City’s Home Program manual adopted on July 1, 2022, at least 20 percent of the HOME assisted units must be rented to households at or below 50 percent of the area median income. The City is required to perform the inspections under the housing quality standards for these units. Condition - The City’s on site inspections for compliance with the housing quality standards are triggered by the City’s process to audit developers for compliance with HOME eligibility requirements. This basis is more restrictive than federal requirements for housing quality inspections. At the end of an inspection cycle, a certificate of completion is completed and signed by the responsible inspector. The City did not have effective controls to ensure the certificate of completion is reviewed for completeness and accuracy. The City did not inspect 20 percent of the units, as required by its policy. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In the process of understanding the controls over compliance with housing quality standards requirement, we noted that the certificate of completion, which is completed at the end of an inspection cycle, was not consistently reviewed. In addition, in one out the three projects selected for testing for compliance with the housing quality standards, the City did not inspect 20 percent of the units at the property, as outlined in their Home Program manual. Cause and Effect - The controls in place to ensure the certificate of completion is reviewed for completeness and accuracy, including review to ensure 20 percent of the units are inspected, were not in place. The lack of controls resulted in a project not having adequate units reviewed. Furthermore, the lack of controls could result in an instance of noncompliance not being identified. Recommendation - We recommend the City ensure controls are in place to comply with the Home Program manual and federal regulations related to housing quality standards. Views of Responsible Officials and Planned Corrective Actions - The City will review its processes and implement additional controls to ensure certificates of completion are reviewed for completeness and accuracy and to verify 20 percent of the units are inspected to comply with the HOME Program manual and federal regulations related to housing quality standards.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the 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 City is required to complete inspections of HOME assisted units to ensure they meet the HUD housing standards as outlined in 24 CFR 92.251(b) (viii). During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing 1 to 4 units, (b) every two years for projects containing 5 to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on site inspections of rental housing occupied by tenants receiving HOME/HOME ARP assisted tenant based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). Per the City’s Home Program manual adopted on July 1, 2022, at least 20 percent of the HOME assisted units must be rented to households at or below 50 percent of the area median income. The City is required to perform the inspections under the housing quality standards for these units. Condition - The City’s on site inspections for compliance with the housing quality standards are triggered by the City’s process to audit developers for compliance with HOME eligibility requirements. This basis is more restrictive than federal requirements for housing quality inspections. At the end of an inspection cycle, a certificate of completion is completed and signed by the responsible inspector. The City did not have effective controls to ensure the certificate of completion is reviewed for completeness and accuracy. The City did not inspect 20 percent of the units, as required by its policy. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In the process of understanding the controls over compliance with housing quality standards requirement, we noted that the certificate of completion, which is completed at the end of an inspection cycle, was not consistently reviewed. In addition, in one out the three projects selected for testing for compliance with the housing quality standards, the City did not inspect 20 percent of the units at the property, as outlined in their Home Program manual. Cause and Effect - The controls in place to ensure the certificate of completion is reviewed for completeness and accuracy, including review to ensure 20 percent of the units are inspected, were not in place. The lack of controls resulted in a project not having adequate units reviewed. Furthermore, the lack of controls could result in an instance of noncompliance not being identified. Recommendation - We recommend the City ensure controls are in place to comply with the Home Program manual and federal regulations related to housing quality standards. Views of Responsible Officials and Planned Corrective Actions - The City will review its processes and implement additional controls to ensure certificates of completion are reviewed for completeness and accuracy and to verify 20 percent of the units are inspected to comply with the HOME Program manual and federal regulations related to housing quality standards.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City is required to track and report program income within HUD’s Integrated Disbursement and Information System (IDIS) and the general ledger. The City reported fiscal 2024 program income in fiscal 2025. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The repayments of principal and interest provided to developers with HOME funds constitute program income. Approximately $2.2 million received in program income during fiscal year 2024 was reported within IDIS and the City’s general ledger in fiscal year 2025. Cause and Effect - The City has a process to reconcile program income received each month to the monthly bank statements; however, the controls in place did not ensure that program income was reported within IDIS and the general ledger in a timely manner. As a result, program income revenue for fiscal year 2024 was initially understated in the general ledger, which was subsequently corrected to be reflected in fiscal year 2024. Additionally, within IDIS, program income was not reported as available for fiscal year 2024 expenditures. Recommendation - We recommend the City ensure controls are in place to track and report program income in a timely manner, in both the general ledger and IDIS. Views of Responsible Officials and Planned Corrective Actions - Management understands the importance of timely reconciliation and reporting of program income to maintain compliance and ensure accurate financial reporting. The City will work to enhance controls and processes with the department stakeholders and monitor the process to ensure timely and consistent receipts of the program income and reconciliations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City is required to track and report program income within HUD’s Integrated Disbursement and Information System (IDIS) and the general ledger. The City reported fiscal 2024 program income in fiscal 2025. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The repayments of principal and interest provided to developers with HOME funds constitute program income. Approximately $2.2 million received in program income during fiscal year 2024 was reported within IDIS and the City’s general ledger in fiscal year 2025. Cause and Effect - The City has a process to reconcile program income received each month to the monthly bank statements; however, the controls in place did not ensure that program income was reported within IDIS and the general ledger in a timely manner. As a result, program income revenue for fiscal year 2024 was initially understated in the general ledger, which was subsequently corrected to be reflected in fiscal year 2024. Additionally, within IDIS, program income was not reported as available for fiscal year 2024 expenditures. Recommendation - We recommend the City ensure controls are in place to track and report program income in a timely manner, in both the general ledger and IDIS. Views of Responsible Officials and Planned Corrective Actions - Management understands the importance of timely reconciliation and reporting of program income to maintain compliance and ensure accurate financial reporting. The City will work to enhance controls and processes with the department stakeholders and monitor the process to ensure timely and consistent receipts of the program income and reconciliations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City is required to track and report program income within HUD’s Integrated Disbursement and Information System (IDIS) and the general ledger. The City reported fiscal 2024 program income in fiscal 2025. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The repayments of principal and interest provided to developers with HOME funds constitute program income. Approximately $2.2 million received in program income during fiscal year 2024 was reported within IDIS and the City’s general ledger in fiscal year 2025. Cause and Effect - The City has a process to reconcile program income received each month to the monthly bank statements; however, the controls in place did not ensure that program income was reported within IDIS and the general ledger in a timely manner. As a result, program income revenue for fiscal year 2024 was initially understated in the general ledger, which was subsequently corrected to be reflected in fiscal year 2024. Additionally, within IDIS, program income was not reported as available for fiscal year 2024 expenditures. Recommendation - We recommend the City ensure controls are in place to track and report program income in a timely manner, in both the general ledger and IDIS. Views of Responsible Officials and Planned Corrective Actions - Management understands the importance of timely reconciliation and reporting of program income to maintain compliance and ensure accurate financial reporting. The City will work to enhance controls and processes with the department stakeholders and monitor the process to ensure timely and consistent receipts of the program income and reconciliations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - The HOME program has income targeting requirements such that only low income or very low income persons can receive housing assistance as prescribed by 24 CFR 92.216. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were reviewed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into an agreement with a contractor to perform eligibility reviews over developers’ determinations of income eligibility. While the City arranges for the contractor to perform the review of eligibility, the City is fully responsible for compliance with eligibility requirements. Testing revealed that the City contractor reviewed the developers’ income eligibility determinations of individuals and families living in HOME funded housing units. In 7 out of a sample of 10 projects, there was no evidence of the City’s review of the contractor’s work. Cause and Effect - In the current year, the City contracted with a contractor to perform eligibility reviews over developers’ determination of income eligibility. However, the City did not implement controls to ensure eligibility reviews performed by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor’s procedures to assess participant eligibility, ineligible participants could receive program benefits, resulting in material noncompliance and the need to repay the funder for such costs. Recommendation - We recommend the City develop oversight procedures to perform a documented review of the work completed by contractors, which pertains to compliance requirements and programmatic decisions, in this case, eligibility review. Views of Responsible Officials and Planned Corrective Actions - The City will implement a control for completeness and accuracy by hosting regular meetings with the contractor to review recent projects for which the contractor has documented their determinations of income eligibility. When a recently reviewed project is not due for an annual review, staff will still have timely insight into the income eligibility of properties in its HOME portfolio, thereby maintaining compliance with HOME program regulations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - The HOME program has income targeting requirements such that only low income or very low income persons can receive housing assistance as prescribed by 24 CFR 92.216. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were reviewed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into an agreement with a contractor to perform eligibility reviews over developers’ determinations of income eligibility. While the City arranges for the contractor to perform the review of eligibility, the City is fully responsible for compliance with eligibility requirements. Testing revealed that the City contractor reviewed the developers’ income eligibility determinations of individuals and families living in HOME funded housing units. In 7 out of a sample of 10 projects, there was no evidence of the City’s review of the contractor’s work. Cause and Effect - In the current year, the City contracted with a contractor to perform eligibility reviews over developers’ determination of income eligibility. However, the City did not implement controls to ensure eligibility reviews performed by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor’s procedures to assess participant eligibility, ineligible participants could receive program benefits, resulting in material noncompliance and the need to repay the funder for such costs. Recommendation - We recommend the City develop oversight procedures to perform a documented review of the work completed by contractors, which pertains to compliance requirements and programmatic decisions, in this case, eligibility review. Views of Responsible Officials and Planned Corrective Actions - The City will implement a control for completeness and accuracy by hosting regular meetings with the contractor to review recent projects for which the contractor has documented their determinations of income eligibility. When a recently reviewed project is not due for an annual review, staff will still have timely insight into the income eligibility of properties in its HOME portfolio, thereby maintaining compliance with HOME program regulations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - The HOME program has income targeting requirements such that only low income or very low income persons can receive housing assistance as prescribed by 24 CFR 92.216. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were reviewed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into an agreement with a contractor to perform eligibility reviews over developers’ determinations of income eligibility. While the City arranges for the contractor to perform the review of eligibility, the City is fully responsible for compliance with eligibility requirements. Testing revealed that the City contractor reviewed the developers’ income eligibility determinations of individuals and families living in HOME funded housing units. In 7 out of a sample of 10 projects, there was no evidence of the City’s review of the contractor’s work. Cause and Effect - In the current year, the City contracted with a contractor to perform eligibility reviews over developers’ determination of income eligibility. However, the City did not implement controls to ensure eligibility reviews performed by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor’s procedures to assess participant eligibility, ineligible participants could receive program benefits, resulting in material noncompliance and the need to repay the funder for such costs. Recommendation - We recommend the City develop oversight procedures to perform a documented review of the work completed by contractors, which pertains to compliance requirements and programmatic decisions, in this case, eligibility review. Views of Responsible Officials and Planned Corrective Actions - The City will implement a control for completeness and accuracy by hosting regular meetings with the contractor to review recent projects for which the contractor has documented their determinations of income eligibility. When a recently reviewed project is not due for an annual review, staff will still have timely insight into the income eligibility of properties in its HOME portfolio, thereby maintaining compliance with HOME program regulations.
2024-001 Entity: Antonia Pantoja Charter School Federal agency: U.S. Department of Education Federal program: COVID-19 Education Stabilization Fund: American Rescue Plan - Elementary and Secondary Schools Emergency Relief Funds Assistance Listing Number: 84.425U ESSER Federal Award Identification Number and Year: S425U210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 223-21-1073 ESSER and 225-21-1073 ESSER Award Period: 03/13/2020 - 09/30/2024 ESSER Type of Finding: • Other Matter • Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Organization is responsible for having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash on Hand – Quarterly Report is a required filing for projects that received payments in a previous quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of Education’s Financial Accounting Information website, we noted there were five Reconciliation of Cash on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: One report was late for a month as a result of the extensive reconciliations and expense reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late due to the change of the portal and the process the PA Department of Education managed for the grant Final Expenditure Report. The portal availability was well after the deadline. Effect: Noncompliance with the reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the scheduled monthly payments to be suspended due to the delinquent submission of the Reconciliation of Cash on Hand – Quarterly Report. Recommendation: To ensure accountability with the required reporting to the Pennsylvania Department of Education, we recommend management review and update procedures to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Views of Responsible Officials: Management agrees with the finding.
2024-001 Entity: Antonia Pantoja Charter School Federal agency: U.S. Department of Education Federal program: COVID-19 Education Stabilization Fund: American Rescue Plan - Elementary and Secondary Schools Emergency Relief Funds Assistance Listing Number: 84.425U ESSER Federal Award Identification Number and Year: S425U210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 223-21-1073 ESSER and 225-21-1073 ESSER Award Period: 03/13/2020 - 09/30/2024 ESSER Type of Finding: • Other Matter • Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Organization is responsible for having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash on Hand – Quarterly Report is a required filing for projects that received payments in a previous quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of Education’s Financial Accounting Information website, we noted there were five Reconciliation of Cash on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: One report was late for a month as a result of the extensive reconciliations and expense reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late due to the change of the portal and the process the PA Department of Education managed for the grant Final Expenditure Report. The portal availability was well after the deadline. Effect: Noncompliance with the reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the scheduled monthly payments to be suspended due to the delinquent submission of the Reconciliation of Cash on Hand – Quarterly Report. Recommendation: To ensure accountability with the required reporting to the Pennsylvania Department of Education, we recommend management review and update procedures to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Views of Responsible Officials: Management agrees with the finding.
2024-001 Entity: Antonia Pantoja Charter School Federal agency: U.S. Department of Education Federal program: COVID-19 Education Stabilization Fund: American Rescue Plan - Elementary and Secondary Schools Emergency Relief Funds Assistance Listing Number: 84.425U ESSER Federal Award Identification Number and Year: S425U210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 223-21-1073 ESSER and 225-21-1073 ESSER Award Period: 03/13/2020 - 09/30/2024 ESSER Type of Finding: • Other Matter • Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Organization is responsible for having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash on Hand – Quarterly Report is a required filing for projects that received payments in a previous quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of Education’s Financial Accounting Information website, we noted there were five Reconciliation of Cash on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: One report was late for a month as a result of the extensive reconciliations and expense reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late due to the change of the portal and the process the PA Department of Education managed for the grant Final Expenditure Report. The portal availability was well after the deadline. Effect: Noncompliance with the reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the scheduled monthly payments to be suspended due to the delinquent submission of the Reconciliation of Cash on Hand – Quarterly Report. Recommendation: To ensure accountability with the required reporting to the Pennsylvania Department of Education, we recommend management review and update procedures to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Views of Responsible Officials: Management agrees with the finding.
2024-001 Entity: Antonia Pantoja Charter School Federal agency: U.S. Department of Education Federal program: COVID-19 Education Stabilization Fund: American Rescue Plan - Elementary and Secondary Schools Emergency Relief Funds Assistance Listing Number: 84.425U ESSER Federal Award Identification Number and Year: S425U210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 223-21-1073 ESSER and 225-21-1073 ESSER Award Period: 03/13/2020 - 09/30/2024 ESSER Type of Finding: • Other Matter • Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Organization is responsible for having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash on Hand – Quarterly Report is a required filing for projects that received payments in a previous quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of Education’s Financial Accounting Information website, we noted there were five Reconciliation of Cash on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: One report was late for a month as a result of the extensive reconciliations and expense reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late due to the change of the portal and the process the PA Department of Education managed for the grant Final Expenditure Report. The portal availability was well after the deadline. Effect: Noncompliance with the reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the scheduled monthly payments to be suspended due to the delinquent submission of the Reconciliation of Cash on Hand – Quarterly Report. Recommendation: To ensure accountability with the required reporting to the Pennsylvania Department of Education, we recommend management review and update procedures to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Views of Responsible Officials: Management agrees with the finding.
2024-001 Entity: Antonia Pantoja Charter School Federal agency: U.S. Department of Education Federal program: COVID-19 Education Stabilization Fund: American Rescue Plan - Elementary and Secondary Schools Emergency Relief Funds Assistance Listing Number: 84.425U ESSER Federal Award Identification Number and Year: S425U210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 223-21-1073 ESSER and 225-21-1073 ESSER Award Period: 03/13/2020 - 09/30/2024 ESSER Type of Finding: • Other Matter • Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Organization is responsible for having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash on Hand – Quarterly Report is a required filing for projects that received payments in a previous quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of Education’s Financial Accounting Information website, we noted there were five Reconciliation of Cash on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: One report was late for a month as a result of the extensive reconciliations and expense reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late due to the change of the portal and the process the PA Department of Education managed for the grant Final Expenditure Report. The portal availability was well after the deadline. Effect: Noncompliance with the reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the scheduled monthly payments to be suspended due to the delinquent submission of the Reconciliation of Cash on Hand – Quarterly Report. Recommendation: To ensure accountability with the required reporting to the Pennsylvania Department of Education, we recommend management review and update procedures to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Views of Responsible Officials: Management agrees with the finding.
2024-001 Entity: Antonia Pantoja Charter School Federal agency: U.S. Department of Education Federal program: COVID-19 Education Stabilization Fund: American Rescue Plan - Elementary and Secondary Schools Emergency Relief Funds Assistance Listing Number: 84.425U ESSER Federal Award Identification Number and Year: S425U210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 223-21-1073 ESSER and 225-21-1073 ESSER Award Period: 03/13/2020 - 09/30/2024 ESSER Type of Finding: • Other Matter • Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Organization is responsible for having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash on Hand – Quarterly Report is a required filing for projects that received payments in a previous quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of Education’s Financial Accounting Information website, we noted there were five Reconciliation of Cash on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: One report was late for a month as a result of the extensive reconciliations and expense reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late due to the change of the portal and the process the PA Department of Education managed for the grant Final Expenditure Report. The portal availability was well after the deadline. Effect: Noncompliance with the reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the scheduled monthly payments to be suspended due to the delinquent submission of the Reconciliation of Cash on Hand – Quarterly Report. Recommendation: To ensure accountability with the required reporting to the Pennsylvania Department of Education, we recommend management review and update procedures to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Views of Responsible Officials: Management agrees with the finding.
Entity: Eugenio Maria de Hostos Charter School Federal agency: U.S. Department of Education Federal program: COVID-19 Education Stabilization Fund: American Rescue Plan – Elementary and Secondary Schools Emergency Relief Fund Assistance Listing Number: 84.425U ESSER Federal Award Identification Number and Year: S425U210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 223-21-0837 ESSER and 225-21-0837 ESSER Award Period: 03/13/2020 - 09/30/2024 ESSER Type of Finding: • Other Matter • Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 Organization is responsible for having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash on Hand – Quarterly Report is a required filing for projects that received payments in a previous quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of Education’s Financial Accounting Information website, we noted there were five Reconciliation of Cash on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: One report was late for a month as a result of the extensive reconciliations and expense reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late due to the change of the portal and the process the PA Department of Education managed for the grant Final Expenditure Report. The portal availability was well after the deadline. Effect: Noncompliance with the reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the scheduled monthly payments to be suspended due to the delinquent submission of the Reconciliation of Cash on Hand – Quarterly Report. Recommendation: To ensure accountability with the required reporting to the Pennsylvania Department of Education, we recommend management review and update procedures to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Views of Responsible Officials: Management agrees with the finding.
Entity: Eugenio Maria de Hostos Charter School Federal agency: U.S. Department of Education Federal program: COVID-19 Education Stabilization Fund: American Rescue Plan – Elementary and Secondary Schools Emergency Relief Fund Assistance Listing Number: 84.425U ESSER Federal Award Identification Number and Year: S425U210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 223-21-0837 ESSER and 225-21-0837 ESSER Award Period: 03/13/2020 - 09/30/2024 ESSER Type of Finding: • Other Matter • Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 Organization is responsible for having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash on Hand – Quarterly Report is a required filing for projects that received payments in a previous quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of Education’s Financial Accounting Information website, we noted there were five Reconciliation of Cash on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: One report was late for a month as a result of the extensive reconciliations and expense reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late due to the change of the portal and the process the PA Department of Education managed for the grant Final Expenditure Report. The portal availability was well after the deadline. Effect: Noncompliance with the reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the scheduled monthly payments to be suspended due to the delinquent submission of the Reconciliation of Cash on Hand – Quarterly Report. Recommendation: To ensure accountability with the required reporting to the Pennsylvania Department of Education, we recommend management review and update procedures to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Views of Responsible Officials: Management agrees with the finding.
Entity: Eugenio Maria de Hostos Charter School Federal agency: U.S. Department of Education Federal program: COVID-19 Education Stabilization Fund: American Rescue Plan – Elementary and Secondary Schools Emergency Relief Fund Assistance Listing Number: 84.425U ESSER Federal Award Identification Number and Year: S425U210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 223-21-0837 ESSER and 225-21-0837 ESSER Award Period: 03/13/2020 - 09/30/2024 ESSER Type of Finding: • Other Matter • Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 Organization is responsible for having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash on Hand – Quarterly Report is a required filing for projects that received payments in a previous quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of Education’s Financial Accounting Information website, we noted there were five Reconciliation of Cash on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: One report was late for a month as a result of the extensive reconciliations and expense reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late due to the change of the portal and the process the PA Department of Education managed for the grant Final Expenditure Report. The portal availability was well after the deadline. Effect: Noncompliance with the reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the scheduled monthly payments to be suspended due to the delinquent submission of the Reconciliation of Cash on Hand – Quarterly Report. Recommendation: To ensure accountability with the required reporting to the Pennsylvania Department of Education, we recommend management review and update procedures to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Views of Responsible Officials: Management agrees with the finding.
Entity: Eugenio Maria de Hostos Charter School Federal agency: U.S. Department of Education Federal program: COVID-19 Education Stabilization Fund: American Rescue Plan – Elementary and Secondary Schools Emergency Relief Fund Assistance Listing Number: 84.425U ESSER Federal Award Identification Number and Year: S425U210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 223-21-0837 ESSER and 225-21-0837 ESSER Award Period: 03/13/2020 - 09/30/2024 ESSER Type of Finding: • Other Matter • Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 Organization is responsible for having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash on Hand – Quarterly Report is a required filing for projects that received payments in a previous quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of Education’s Financial Accounting Information website, we noted there were five Reconciliation of Cash on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: One report was late for a month as a result of the extensive reconciliations and expense reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late due to the change of the portal and the process the PA Department of Education managed for the grant Final Expenditure Report. The portal availability was well after the deadline. Effect: Noncompliance with the reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the scheduled monthly payments to be suspended due to the delinquent submission of the Reconciliation of Cash on Hand – Quarterly Report. Recommendation: To ensure accountability with the required reporting to the Pennsylvania Department of Education, we recommend management review and update procedures to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Views of Responsible Officials: Management agrees with the finding.
Entity: Eugenio Maria de Hostos Charter School Federal agency: U.S. Department of Education Federal program: COVID-19 Education Stabilization Fund: American Rescue Plan – Elementary and Secondary Schools Emergency Relief Fund Assistance Listing Number: 84.425U ESSER Federal Award Identification Number and Year: S425U210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 223-21-0837 ESSER and 225-21-0837 ESSER Award Period: 03/13/2020 - 09/30/2024 ESSER Type of Finding: • Other Matter • Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 Organization is responsible for having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash on Hand – Quarterly Report is a required filing for projects that received payments in a previous quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of Education’s Financial Accounting Information website, we noted there were five Reconciliation of Cash on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: One report was late for a month as a result of the extensive reconciliations and expense reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late due to the change of the portal and the process the PA Department of Education managed for the grant Final Expenditure Report. The portal availability was well after the deadline. Effect: Noncompliance with the reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the scheduled monthly payments to be suspended due to the delinquent submission of the Reconciliation of Cash on Hand – Quarterly Report. Recommendation: To ensure accountability with the required reporting to the Pennsylvania Department of Education, we recommend management review and update procedures to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Views of Responsible Officials: Management agrees with the finding.
Entity: Eugenio Maria de Hostos Charter School Federal agency: U.S. Department of Education Federal program: COVID-19 Education Stabilization Fund: American Rescue Plan – Elementary and Secondary Schools Emergency Relief Fund Assistance Listing Number: 84.425U ESSER Federal Award Identification Number and Year: S425U210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 223-21-0837 ESSER and 225-21-0837 ESSER Award Period: 03/13/2020 - 09/30/2024 ESSER Type of Finding: • Other Matter • Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 Organization is responsible for having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash on Hand – Quarterly Report is a required filing for projects that received payments in a previous quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of Education’s Financial Accounting Information website, we noted there were five Reconciliation of Cash on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: One report was late for a month as a result of the extensive reconciliations and expense reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late due to the change of the portal and the process the PA Department of Education managed for the grant Final Expenditure Report. The portal availability was well after the deadline. Effect: Noncompliance with the reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the scheduled monthly payments to be suspended due to the delinquent submission of the Reconciliation of Cash on Hand – Quarterly Report. Recommendation: To ensure accountability with the required reporting to the Pennsylvania Department of Education, we recommend management review and update procedures to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Views of Responsible Officials: Management agrees with the finding.
Entity: Eugenio Maria de Hostos Charter School Federal agency: U.S. Department of Education Federal program: COVID-19 Education Stabilization Fund: American Rescue Plan – Elementary and Secondary Schools Emergency Relief Fund Assistance Listing Number: 84.425U ESSER Federal Award Identification Number and Year: S425U210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 223-21-0837 ESSER and 225-21-0837 ESSER Award Period: 03/13/2020 - 09/30/2024 ESSER Type of Finding: • Other Matter • Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 Organization is responsible for having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash on Hand – Quarterly Report is a required filing for projects that received payments in a previous quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of Education’s Financial Accounting Information website, we noted there were five Reconciliation of Cash on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: One report was late for a month as a result of the extensive reconciliations and expense reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late due to the change of the portal and the process the PA Department of Education managed for the grant Final Expenditure Report. The portal availability was well after the deadline. Effect: Noncompliance with the reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the scheduled monthly payments to be suspended due to the delinquent submission of the Reconciliation of Cash on Hand – Quarterly Report. Recommendation: To ensure accountability with the required reporting to the Pennsylvania Department of Education, we recommend management review and update procedures to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Views of Responsible Officials: Management agrees with the finding.
2024-002 Special Tests and Provisions Federal agency: U.S Department of Education Federal program title: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268 Federal Award Identification Number: P007A233410, P033A233410, P063P232032, P268K24032 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Compliance, Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1) an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 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. Condition: The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and returned funds late. Context: During our testing, we identified 3 out of 40 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, 2 out of 40 of the R2T4 selections had funds that were not returned timely (after 45 days). Questioned costs: None. Cause: The College input the incorrect dates when completing R2T4 calculations. Effect: The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately and federal funds are returned timely. Views of responsible officials: Management agrees with the finding.
2024-002 Special Tests and Provisions Federal agency: U.S Department of Education Federal program title: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268 Federal Award Identification Number: P007A233410, P033A233410, P063P232032, P268K24032 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Compliance, Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1) an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 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. Condition: The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and returned funds late. Context: During our testing, we identified 3 out of 40 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, 2 out of 40 of the R2T4 selections had funds that were not returned timely (after 45 days). Questioned costs: None. Cause: The College input the incorrect dates when completing R2T4 calculations. Effect: The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately and federal funds are returned timely. Views of responsible officials: Management agrees with the finding.
2024-002 Special Tests and Provisions Federal agency: U.S Department of Education Federal program title: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268 Federal Award Identification Number: P007A233410, P033A233410, P063P232032, P268K24032 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Compliance, Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1) an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 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. Condition: The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and returned funds late. Context: During our testing, we identified 3 out of 40 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, 2 out of 40 of the R2T4 selections had funds that were not returned timely (after 45 days). Questioned costs: None. Cause: The College input the incorrect dates when completing R2T4 calculations. Effect: The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately and federal funds are returned timely. Views of responsible officials: Management agrees with the finding.
2024-002 Special Tests and Provisions Federal agency: U.S Department of Education Federal program title: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268 Federal Award Identification Number: P007A233410, P033A233410, P063P232032, P268K24032 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Compliance, Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1) an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 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. Condition: The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and returned funds late. Context: During our testing, we identified 3 out of 40 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, 2 out of 40 of the R2T4 selections had funds that were not returned timely (after 45 days). Questioned costs: None. Cause: The College input the incorrect dates when completing R2T4 calculations. Effect: The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately and federal funds are returned timely. Views of responsible officials: Management agrees with the finding.
2024-003 Allowable Costs Federal agency: U.S Department of Education & Department of Health and Human Services Federal program title: Career and Technical Education - Basic Grant to States & Child Care and Development Block Grant Assistant Listing Number: 84.048 & 93.575 Federal Award Identification Number: V048A220030-2024 and 2101ILccc5-2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Compliance, Other Matters Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.430(g)(1) states charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. 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. Condition: The College did not have proper documentation of Time and Effort reporting. Context: During our testing, we identified that time and effort reports were not documented properly to track hours worked on federal grant and did not have documentation of formal review. Questioned costs: None. Cause: The College did not have proper procedures in place to track time and effort for personnel on federal grants. Effect: The College could potentially expense incorrect amount to federal grants. Repeat Finding: No. Recommendation: We recommend the College review policies and procedures to ensure all personnel on federal grants have documented time and effort reports as stated in federal regulations. Views of responsible officials: Management agrees with the finding.
2024-003 Allowable Costs Federal agency: U.S Department of Education & Department of Health and Human Services Federal program title: Career and Technical Education - Basic Grant to States & Child Care and Development Block Grant Assistant Listing Number: 84.048 & 93.575 Federal Award Identification Number: V048A220030-2024 and 2101ILccc5-2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Compliance, Other Matters Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.430(g)(1) states charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. 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. Condition: The College did not have proper documentation of Time and Effort reporting. Context: During our testing, we identified that time and effort reports were not documented properly to track hours worked on federal grant and did not have documentation of formal review. Questioned costs: None. Cause: The College did not have proper procedures in place to track time and effort for personnel on federal grants. Effect: The College could potentially expense incorrect amount to federal grants. Repeat Finding: No. Recommendation: We recommend the College review policies and procedures to ensure all personnel on federal grants have documented time and effort reports as stated in federal regulations. Views of responsible officials: Management agrees with the finding.
2024-001 Reporting Federal agency: U.S Department of Commerce Federal program title: Investments for Public Works and Economic Development Facilities Assistant Listing Number: 11.300 Federal Award Identification Number: 05-79-06232 - 2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Compliance, Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 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 reports are formally reviewed by someone who did not prepare the report to verify the correct information and data is submitted. Additionally, per 2 CFR 200.328(c) the recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Condition: The College did not have a formal review process in place as well as submit report timely. Context: During our testing, we identified 2 out of 2 financial reports did not have documentation of formal review. Additionally, 1 of the 2 reports was not submitted within the required timeframe. Questioned costs: None. Cause: Supervisory review and approval is currently undocumented, and is only communicated verbally. Effect: Improper data could be submitted to the awarding agency. Repeat Finding: No. Recommendation: The College should implement formal review procedures to document review and approvals over required reports in addition to procedures to ensure reports are being submitted timely. Views of responsible officials: Management agrees with the finding.
2024-005: U.S. Department of Education Passed through State of Nevada Department of Education Supporting Effective Instruction State Grants, 84.367 Matching, Level of Effort, and Earmarking Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing number 84.367 on the Schedule of Expenditures of Federal Awards. 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) section 200.303 provides that non-federal entities must establish and maintain effective internal control 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. Condition: Underlying supporting documentation that the Elko County School District compiled to monitor local compliance with level of effort requirements was not maintained. Cause: Elko County School District did not have sufficient internal controls to ensure level of effort tracking was maintained and reviewed. Effect: Noncompliance with level of effort requirements may not be detected. Questioned Costs: None Context/Sampling: Underlying supporting documentation for monitoring was not maintained. A recalculation of the level of effort requirements, as applicable, for the fiscal year ending June 30, 2024, was performed and no issues of noncompliance were noted. Repeat Finding from Prior Year(s): No Recommendation: We recommend Elko County School District enhance internal controls to ensure information used in the level of effort monitoring is maintained. Views of Responsible Officials: Management agrees with the finding.
2024-005: U.S. Department of Education Passed through State of Nevada Department of Education Supporting Effective Instruction State Grants, 84.367 Matching, Level of Effort, and Earmarking Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing number 84.367 on the Schedule of Expenditures of Federal Awards. 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) section 200.303 provides that non-federal entities must establish and maintain effective internal control 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. Condition: Underlying supporting documentation that the Elko County School District compiled to monitor local compliance with level of effort requirements was not maintained. Cause: Elko County School District did not have sufficient internal controls to ensure level of effort tracking was maintained and reviewed. Effect: Noncompliance with level of effort requirements may not be detected. Questioned Costs: None Context/Sampling: Underlying supporting documentation for monitoring was not maintained. A recalculation of the level of effort requirements, as applicable, for the fiscal year ending June 30, 2024, was performed and no issues of noncompliance were noted. Repeat Finding from Prior Year(s): No Recommendation: We recommend Elko County School District enhance internal controls to ensure information used in the level of effort monitoring is maintained. Views of Responsible Officials: Management agrees with the finding.
FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) 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). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guidelines used by the food service software. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) 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). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guidelines used by the food service software. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) 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). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guidelines used by the food service software. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) 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). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal review control in place. There is no documented, secondary review for the applications entered in the food service software which determines eligibility. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation's management establish an internal control process to review the updates to the annual adjustments to the Income Eligibility Guidelines made to the food service software to determine eligibility to ensure updated guidelines are accurate and complete. This review should be documented on annual basis to confirm management’s oversight and monitoring of eligibility determinations. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) 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). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal review control in place. There is no documented, secondary review for the applications entered in the food service software which determines eligibility. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation's management establish an internal control process to review the updates to the annual adjustments to the Income Eligibility Guidelines made to the food service software to determine eligibility to ensure updated guidelines are accurate and complete. This review should be documented on annual basis to confirm management’s oversight and monitoring of eligibility determinations. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) 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). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal review control in place. There is no documented, secondary review for the applications entered in the food service software which determines eligibility. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation's management establish an internal control process to review the updates to the annual adjustments to the Income Eligibility Guidelines made to the food service software to determine eligibility to ensure updated guidelines are accurate and complete. This review should be documented on annual basis to confirm management’s oversight and monitoring of eligibility determinations. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Condition: During our audit we noted that management did not have approval controls over invoices reimbursed by the federal program and approval of subrecipient monitoring reports. Criteria: The Organization must establish and maintain effective internal controls over the financial 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 per CFR 200.303. These requirements detail the information that must be included in the Organization's internal control. Cause: Management did not design and implement internal controls to document approval of invoices reimbursed by the federal program and subrecipient monitoring reports. Approvals were obtained verbally and were not documented. Effect: The absence of controls over disbursements and subrecipient monitoring incurred lead to an increased risk of errors and noncompliance in the financial statements, which could misrepresent the Organization's financial statements Recommendation: We recommend that the Organization implements a process to ensure that management documents all approvals and that approvals are occurring by proper personal.
Department of Housing and Urban Development 14.871 Housing Voucher Cluster Internal Control Finding - Eligibility Repeat Finding: No Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The PHA must have sufficient internal controls in place to ensure the proper administration of HUD funding. Condition and Context: We tested a sample of 25 HAP contracts and found 2 tenants where the tenant affidavit for rental assistance benefits was not signed by a housing specialist. Therefore, these two selections did not have evidence that the tenant information was reviewed. Cause: The City does not have a proper policy in place to ensure documentation of review procedures. Effect or Potential Effect: The City could potentially create a HAP contract with a tenant that is ineligible for rental assistance. Questioned Costs: Unknown. Recommendation: We recommend that tenant evaluations and annual re-evaluations are reviewed by a supervisor prior to creating a HAP contract or renewing an existing contract to ensure tenant files are properly reviewed and documented. Views of Responsible Officials: The City agrees with the finding. See Section V for the corrective action plan.
Department of Housing and Urban Development 14.871 Housing Voucher Cluster Internal Control Finding - Eligibility Repeat Finding: No Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The PHA must have sufficient internal controls in place to ensure the proper administration of HUD funding. Condition and Context: We tested a sample of 25 HAP contracts and found 2 tenants where the tenant affidavit for rental assistance benefits was not signed by a housing specialist. Therefore, these two selections did not have evidence that the tenant information was reviewed. Cause: The City does not have a proper policy in place to ensure documentation of review procedures. Effect or Potential Effect: The City could potentially create a HAP contract with a tenant that is ineligible for rental assistance. Questioned Costs: Unknown. Recommendation: We recommend that tenant evaluations and annual re-evaluations are reviewed by a supervisor prior to creating a HAP contract or renewing an existing contract to ensure tenant files are properly reviewed and documented. Views of Responsible Officials: The City agrees with the finding. See Section V for the corrective action plan.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness 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 the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness 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 the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.