2024-002 Lack of Report Review 21.027 COVID-19 Coronavirus & Local Fiscal Recovery Funds US Department of the Treasury Passed through Florida Department of Environmental Protection 2024 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Reports should be subject to independent review to verify completeness, validity and timeliness of submission. Various reports are required to be submitted throughout the course of the work, as per the grant agreements between the City and Florida Department of Environmental Protection. Condition: Quarterly reports were not reviewed throughout the period under audit. Cause of condition: There is no process to document review of reports submitted to Florida Department of Environmental Protection. Potential effect of condition: Reports submitted to Florida Department of Environmental Protection may be incomplete, include errors, or be submitted late. Questioned Costs: None. Recommendation: Review of reports should be documented prior to submission to the grantor. Management’s response on planned corrective action: The City has worked and will continue to work diligently on this issue. The City is working to ensure that all reports are properly reviewed prior to submission and that evidence of the review process is properly documented.
2024-002 Lack of Report Review 21.027 COVID-19 Coronavirus & Local Fiscal Recovery Funds US Department of the Treasury Passed through Florida Department of Environmental Protection 2024 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Reports should be subject to independent review to verify completeness, validity and timeliness of submission. Various reports are required to be submitted throughout the course of the work, as per the grant agreements between the City and Florida Department of Environmental Protection. Condition: Quarterly reports were not reviewed throughout the period under audit. Cause of condition: There is no process to document review of reports submitted to Florida Department of Environmental Protection. Potential effect of condition: Reports submitted to Florida Department of Environmental Protection may be incomplete, include errors, or be submitted late. Questioned Costs: None. Recommendation: Review of reports should be documented prior to submission to the grantor. Management’s response on planned corrective action: The City has worked and will continue to work diligently on this issue. The City is working to ensure that all reports are properly reviewed prior to submission and that evidence of the review process is properly documented.
2024-003 Suspension and Debarment 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds US Department of Treasury Passed through Florida Department of Environmental Protection 2024 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. 2 CFR 180 prohibits entering into covered transactions with entities that have been suspended or debarred from Federal funding. Documentation of the check for suspension or debarment needs to be retained. Condition: Review of checking for suspension and debarment was not done prior to contracting with the vendor. Cause of condition: There is no consistent process to ensure that the vendors were not suspended and debarred, prior to procuring goods or services. Perspective (context): For 29 of the 37 invoices selected, suspension and debarment was not checked prior to paying the vendor. Potential effect of condition: Good or services could be contracted with a suspended or debarred vendor, creating questioned costs. Questioned Costs: None. Recommendation: Review of vendors suspension and debarment should be done prior to entering into a contract or obtaining good or services. Management’s response on planned corrective action: The City has worked and will continue to work diligently on this issue. The City is working to ensure that all vendors are properly reviewed for suspension and debarment on an ongoing basis.
2024-003 Suspension and Debarment 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds US Department of Treasury Passed through Florida Department of Environmental Protection 2024 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. 2 CFR 180 prohibits entering into covered transactions with entities that have been suspended or debarred from Federal funding. Documentation of the check for suspension or debarment needs to be retained. Condition: Review of checking for suspension and debarment was not done prior to contracting with the vendor. Cause of condition: There is no consistent process to ensure that the vendors were not suspended and debarred, prior to procuring goods or services. Perspective (context): For 29 of the 37 invoices selected, suspension and debarment was not checked prior to paying the vendor. Potential effect of condition: Good or services could be contracted with a suspended or debarred vendor, creating questioned costs. Questioned Costs: None. Recommendation: Review of vendors suspension and debarment should be done prior to entering into a contract or obtaining good or services. Management’s response on planned corrective action: The City has worked and will continue to work diligently on this issue. The City is working to ensure that all vendors are properly reviewed for suspension and debarment on an ongoing basis.
2024-003 Suspension and Debarment 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds US Department of Treasury Passed through Florida Department of Environmental Protection 2024 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. 2 CFR 180 prohibits entering into covered transactions with entities that have been suspended or debarred from Federal funding. Documentation of the check for suspension or debarment needs to be retained. Condition: Review of checking for suspension and debarment was not done prior to contracting with the vendor. Cause of condition: There is no consistent process to ensure that the vendors were not suspended and debarred, prior to procuring goods or services. Perspective (context): For 29 of the 37 invoices selected, suspension and debarment was not checked prior to paying the vendor. Potential effect of condition: Good or services could be contracted with a suspended or debarred vendor, creating questioned costs. Questioned Costs: None. Recommendation: Review of vendors suspension and debarment should be done prior to entering into a contract or obtaining good or services. Management’s response on planned corrective action: The City has worked and will continue to work diligently on this issue. The City is working to ensure that all vendors are properly reviewed for suspension and debarment on an ongoing basis.
2024-003 Suspension and Debarment 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds US Department of Treasury Passed through Florida Department of Environmental Protection 2024 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. 2 CFR 180 prohibits entering into covered transactions with entities that have been suspended or debarred from Federal funding. Documentation of the check for suspension or debarment needs to be retained. Condition: Review of checking for suspension and debarment was not done prior to contracting with the vendor. Cause of condition: There is no consistent process to ensure that the vendors were not suspended and debarred, prior to procuring goods or services. Perspective (context): For 29 of the 37 invoices selected, suspension and debarment was not checked prior to paying the vendor. Potential effect of condition: Good or services could be contracted with a suspended or debarred vendor, creating questioned costs. Questioned Costs: None. Recommendation: Review of vendors suspension and debarment should be done prior to entering into a contract or obtaining good or services. Management’s response on planned corrective action: The City has worked and will continue to work diligently on this issue. The City is working to ensure that all vendors are properly reviewed for suspension and debarment on an ongoing basis.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Federal Assistance Listing Number: 93.600 Award Period: June 1, 2023 to May 31, 2024, June 1, 2024 to May 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs Criteria or Specific Requirement: Timely review and approval should be maintained to ensure accurate amounts are being drawdown and accurate reports are submitted. Under 2 CFR section 200.303, a non-federal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Organization did not adequately follow internal controls in place to ensure required reports are approved by the appropriate personnel before being submitted. Questioned Costs: N/A Context: The control in place for internal review prior to submitting financial reports to HS/EHS was not followed for two of the five reports tested. Cause: Management was unable to obtain the signature of the assigned individual due to their unavailability during a break period. Effect: Potential for inaccurate information to be reported. Repeat Finding: No Recommendation: Establish a backup signatory process to ensure that there is always an available individual to provide necessary signatures, even during periods of unavailability. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Federal Assistance Listing Number: 93.600 Award Period: June 1, 2023 to May 31, 2024, June 1, 2024 to May 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs Criteria or Specific Requirement: Timely review and approval should be maintained to ensure accurate amounts are being drawdown and accurate reports are submitted. Under 2 CFR section 200.303, a non-federal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Organization did not adequately follow internal controls in place to ensure required reports are approved by the appropriate personnel before being submitted. Questioned Costs: N/A Context: The control in place for internal review prior to submitting financial reports to HS/EHS was not followed for two of the five reports tested. Cause: Management was unable to obtain the signature of the assigned individual due to their unavailability during a break period. Effect: Potential for inaccurate information to be reported. Repeat Finding: No Recommendation: Establish a backup signatory process to ensure that there is always an available individual to provide necessary signatures, even during periods of unavailability. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Federal Assistance Listing Number: 93.600 Award Period: June 1, 2023 to May 31, 2024, June 1, 2024 to May 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs Criteria or Specific Requirement: Timely review and approval should be maintained to ensure accurate amounts are being drawdown and accurate reports are submitted. Under 2 CFR section 200.303, a non-federal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Organization did not adequately follow internal controls in place to ensure required reports are approved by the appropriate personnel before being submitted. Questioned Costs: N/A Context: The control in place for internal review prior to submitting financial reports to HS/EHS was not followed for two of the five reports tested. Cause: Management was unable to obtain the signature of the assigned individual due to their unavailability during a break period. Effect: Potential for inaccurate information to be reported. Repeat Finding: No Recommendation: Establish a backup signatory process to ensure that there is always an available individual to provide necessary signatures, even during periods of unavailability. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Federal Assistance Listing Number: 93.600 Award Period: June 1, 2023 to May 31, 2024, June 1, 2024 to May 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs Criteria or Specific Requirement: Timely review and approval should be maintained to ensure accurate amounts are being drawdown and accurate reports are submitted. Under 2 CFR section 200.303, a non-federal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Organization did not adequately follow internal controls in place to ensure required reports are approved by the appropriate personnel before being submitted. Questioned Costs: N/A Context: The control in place for internal review prior to submitting financial reports to HS/EHS was not followed for two of the five reports tested. Cause: Management was unable to obtain the signature of the assigned individual due to their unavailability during a break period. Effect: Potential for inaccurate information to be reported. Repeat Finding: No Recommendation: Establish a backup signatory process to ensure that there is always an available individual to provide necessary signatures, even during periods of unavailability. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Federal Assistance Listing Number: 93.600 Award Period: June 1, 2023 to May 31, 2024, June 1, 2024 to May 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Under 2 CFR section 200.303 a non-federal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the no reconciliation of the inventory count to the asset listing. Questioned Costs: N/A Context: There was no documented reconciliation of inventory count. Cause: The Organization performed an inventory count during the fiscal year, however, there were no policies in place to formally document the count, reconcile the count to the asset listing, or review such reconciliation. Effect: Potential for missing, old, or out of use property Repeat Finding: Yes Recommendation: The Organization should perform an inventory count with proper reconciliations to the asset listing, along with having a different individual review and document such review of the count and the reconciliation. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Federal Assistance Listing Number: 93.600 Award Period: June 1, 2023 to May 31, 2024, June 1, 2024 to May 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Under 2 CFR section 200.303 a non-federal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the no reconciliation of the inventory count to the asset listing. Questioned Costs: N/A Context: There was no documented reconciliation of inventory count. Cause: The Organization performed an inventory count during the fiscal year, however, there were no policies in place to formally document the count, reconcile the count to the asset listing, or review such reconciliation. Effect: Potential for missing, old, or out of use property Repeat Finding: Yes Recommendation: The Organization should perform an inventory count with proper reconciliations to the asset listing, along with having a different individual review and document such review of the count and the reconciliation. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Federal Assistance Listing Number: 93.600 Award Period: June 1, 2023 to May 31, 2024, June 1, 2024 to May 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Under 2 CFR section 200.303 a non-federal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the no reconciliation of the inventory count to the asset listing. Questioned Costs: N/A Context: There was no documented reconciliation of inventory count. Cause: The Organization performed an inventory count during the fiscal year, however, there were no policies in place to formally document the count, reconcile the count to the asset listing, or review such reconciliation. Effect: Potential for missing, old, or out of use property Repeat Finding: Yes Recommendation: The Organization should perform an inventory count with proper reconciliations to the asset listing, along with having a different individual review and document such review of the count and the reconciliation. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Federal Assistance Listing Number: 93.600 Award Period: June 1, 2023 to May 31, 2024, June 1, 2024 to May 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Under 2 CFR section 200.303 a non-federal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the no reconciliation of the inventory count to the asset listing. Questioned Costs: N/A Context: There was no documented reconciliation of inventory count. Cause: The Organization performed an inventory count during the fiscal year, however, there were no policies in place to formally document the count, reconcile the count to the asset listing, or review such reconciliation. Effect: Potential for missing, old, or out of use property Repeat Finding: Yes Recommendation: The Organization should perform an inventory count with proper reconciliations to the asset listing, along with having a different individual review and document such review of the count and the reconciliation. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Noncompliance Finding and Significant Deficiency – Reporting Criteria: 2CFR 200.303 establishes that grant recipients should establish, document, and maintain effective internal control over federal awards, including controls over reviews of reports and compliance with reporting requirements. 2 CFR 200.239(c) establishes that grant recipients should submit performance reports timely. Condition: During our testing, D&T inspected 16 programmatic reports whereby there should have been appropriate levels of review and compliance with submission requirements. Two reports were submitted to the granting agency late, 3 reports did not have any evidence of review and approval of the reports prior to submission, and 4 reports did not have proper segregation of duties as related to the preparation and submission of the reports. Cause: For the late reports, department management did not monitor and ensure that the reports were submitted in a timely manner due to other emergency events at the County taking priority. For the reports with lack of review support, management did not maintain supporting documentation of the review performed on the reports prior to submission. Lastly, for the reports without proper segregation of duties, Harris County did not design or implement a segregation of duties control to ensure separate preparer and reviewer. Effect: Failure to review and approve the reports prior to submission to the grantor, late submission of the reports, and lack of segregation of duties increases the risk of submitting an inaccurate report and may result in the early termination of the award, reimbursement of award funds, and cessation of future funding. Recommendation: Management should establish detailed and precise controls to ensure timely reviews, clear identification of preparers and reviewers, and retain evidence of such reviews to ensure compliance with grant requirements. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Richard Williams, Deputy Chief Financial Officer of Harris County Public Health Danielle Calhoun, Associate Director of Harris County Public Health Allison Hare, Director of Public Health Emergency Preparedness Beatrice Best, Lead Grant Program Supervisor of Harris County Public Health
Noncompliance Finding and Significant Deficiency – Reporting Criteria: 2CFR 200.303 establishes that grant recipients should establish, document, and maintain effective internal control over federal awards, including controls over reviews of reports and compliance with reporting requirements. 2 CFR 200.239(c) establishes that grant recipients should submit performance reports timely. Condition: During our testing, D&T inspected 16 programmatic reports whereby there should have been appropriate levels of review and compliance with submission requirements. Two reports were submitted to the granting agency late, 3 reports did not have any evidence of review and approval of the reports prior to submission, and 4 reports did not have proper segregation of duties as related to the preparation and submission of the reports. Cause: For the late reports, department management did not monitor and ensure that the reports were submitted in a timely manner due to other emergency events at the County taking priority. For the reports with lack of review support, management did not maintain supporting documentation of the review performed on the reports prior to submission. Lastly, for the reports without proper segregation of duties, Harris County did not design or implement a segregation of duties control to ensure separate preparer and reviewer. Effect: Failure to review and approve the reports prior to submission to the grantor, late submission of the reports, and lack of segregation of duties increases the risk of submitting an inaccurate report and may result in the early termination of the award, reimbursement of award funds, and cessation of future funding. Recommendation: Management should establish detailed and precise controls to ensure timely reviews, clear identification of preparers and reviewers, and retain evidence of such reviews to ensure compliance with grant requirements. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Richard Williams, Deputy Chief Financial Officer of Harris County Public Health Danielle Calhoun, Associate Director of Harris County Public Health Allison Hare, Director of Public Health Emergency Preparedness Beatrice Best, Lead Grant Program Supervisor of Harris County Public Health
Noncompliance Finding and Significant Deficiency – Reporting Criteria: 2CFR 200.303 establishes that grant recipients should establish, document, and maintain effective internal control over federal awards, including controls over reviews of reports and compliance with reporting requirements. 2 CFR 200.239(c) establishes that grant recipients should submit performance reports timely. Condition: During our testing, D&T inspected 16 programmatic reports whereby there should have been appropriate levels of review and compliance with submission requirements. Two reports were submitted to the granting agency late, 3 reports did not have any evidence of review and approval of the reports prior to submission, and 4 reports did not have proper segregation of duties as related to the preparation and submission of the reports. Cause: For the late reports, department management did not monitor and ensure that the reports were submitted in a timely manner due to other emergency events at the County taking priority. For the reports with lack of review support, management did not maintain supporting documentation of the review performed on the reports prior to submission. Lastly, for the reports without proper segregation of duties, Harris County did not design or implement a segregation of duties control to ensure separate preparer and reviewer. Effect: Failure to review and approve the reports prior to submission to the grantor, late submission of the reports, and lack of segregation of duties increases the risk of submitting an inaccurate report and may result in the early termination of the award, reimbursement of award funds, and cessation of future funding. Recommendation: Management should establish detailed and precise controls to ensure timely reviews, clear identification of preparers and reviewers, and retain evidence of such reviews to ensure compliance with grant requirements. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Richard Williams, Deputy Chief Financial Officer of Harris County Public Health Danielle Calhoun, Associate Director of Harris County Public Health Allison Hare, Director of Public Health Emergency Preparedness Beatrice Best, Lead Grant Program Supervisor of Harris County Public Health
Noncompliance Finding and Significant Deficiency – Reporting Criteria: 2CFR 200.303 establishes that grant recipients should establish, document, and maintain effective internal control over federal awards, including controls over reviews of reports and compliance with reporting requirements. 2 CFR 200.239(c) establishes that grant recipients should submit performance reports timely. Condition: During our testing, D&T inspected 16 programmatic reports whereby there should have been appropriate levels of review and compliance with submission requirements. Two reports were submitted to the granting agency late, 3 reports did not have any evidence of review and approval of the reports prior to submission, and 4 reports did not have proper segregation of duties as related to the preparation and submission of the reports. Cause: For the late reports, department management did not monitor and ensure that the reports were submitted in a timely manner due to other emergency events at the County taking priority. For the reports with lack of review support, management did not maintain supporting documentation of the review performed on the reports prior to submission. Lastly, for the reports without proper segregation of duties, Harris County did not design or implement a segregation of duties control to ensure separate preparer and reviewer. Effect: Failure to review and approve the reports prior to submission to the grantor, late submission of the reports, and lack of segregation of duties increases the risk of submitting an inaccurate report and may result in the early termination of the award, reimbursement of award funds, and cessation of future funding. Recommendation: Management should establish detailed and precise controls to ensure timely reviews, clear identification of preparers and reviewers, and retain evidence of such reviews to ensure compliance with grant requirements. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Richard Williams, Deputy Chief Financial Officer of Harris County Public Health Danielle Calhoun, Associate Director of Harris County Public Health Allison Hare, Director of Public Health Emergency Preparedness Beatrice Best, Lead Grant Program Supervisor of Harris County Public Health
Noncompliance Finding and Significant Deficiency – Reporting Criteria: 2CFR 200.303 establishes that grant recipients should establish, document, and maintain effective internal control over federal awards, including controls over reviews of reports and compliance with reporting requirements. 2 CFR 200.239(c) establishes that grant recipients should submit performance reports timely. Condition: During our testing, D&T inspected 16 programmatic reports whereby there should have been appropriate levels of review and compliance with submission requirements. Two reports were submitted to the granting agency late, 3 reports did not have any evidence of review and approval of the reports prior to submission, and 4 reports did not have proper segregation of duties as related to the preparation and submission of the reports. Cause: For the late reports, department management did not monitor and ensure that the reports were submitted in a timely manner due to other emergency events at the County taking priority. For the reports with lack of review support, management did not maintain supporting documentation of the review performed on the reports prior to submission. Lastly, for the reports without proper segregation of duties, Harris County did not design or implement a segregation of duties control to ensure separate preparer and reviewer. Effect: Failure to review and approve the reports prior to submission to the grantor, late submission of the reports, and lack of segregation of duties increases the risk of submitting an inaccurate report and may result in the early termination of the award, reimbursement of award funds, and cessation of future funding. Recommendation: Management should establish detailed and precise controls to ensure timely reviews, clear identification of preparers and reviewers, and retain evidence of such reviews to ensure compliance with grant requirements. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Richard Williams, Deputy Chief Financial Officer of Harris County Public Health Danielle Calhoun, Associate Director of Harris County Public Health Allison Hare, Director of Public Health Emergency Preparedness Beatrice Best, Lead Grant Program Supervisor of Harris County Public Health
Noncompliance Finding and Significant Deficiency – Reporting Criteria: 2CFR 200.303 establishes that grant recipients should establish, document, and maintain effective internal control over federal awards, including controls over reviews of reports and compliance with reporting requirements. 2 CFR 200.239(c) establishes that grant recipients should submit performance reports timely. Condition: During our testing, D&T inspected 16 programmatic reports whereby there should have been appropriate levels of review and compliance with submission requirements. Two reports were submitted to the granting agency late, 3 reports did not have any evidence of review and approval of the reports prior to submission, and 4 reports did not have proper segregation of duties as related to the preparation and submission of the reports. Cause: For the late reports, department management did not monitor and ensure that the reports were submitted in a timely manner due to other emergency events at the County taking priority. For the reports with lack of review support, management did not maintain supporting documentation of the review performed on the reports prior to submission. Lastly, for the reports without proper segregation of duties, Harris County did not design or implement a segregation of duties control to ensure separate preparer and reviewer. Effect: Failure to review and approve the reports prior to submission to the grantor, late submission of the reports, and lack of segregation of duties increases the risk of submitting an inaccurate report and may result in the early termination of the award, reimbursement of award funds, and cessation of future funding. Recommendation: Management should establish detailed and precise controls to ensure timely reviews, clear identification of preparers and reviewers, and retain evidence of such reviews to ensure compliance with grant requirements. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Richard Williams, Deputy Chief Financial Officer of Harris County Public Health Danielle Calhoun, Associate Director of Harris County Public Health Allison Hare, Director of Public Health Emergency Preparedness Beatrice Best, Lead Grant Program Supervisor of Harris County Public Health
Noncompliance Finding and Significant Deficiency – Reporting Criteria: 2CFR 200.303 establishes that grant recipients should establish, document, and maintain effective internal control over federal awards, including controls over reviews of reports and compliance with reporting requirements. 2 CFR 200.239(c) establishes that grant recipients should submit performance reports timely. Condition: During our testing, D&T inspected 16 programmatic reports whereby there should have been appropriate levels of review and compliance with submission requirements. Two reports were submitted to the granting agency late, 3 reports did not have any evidence of review and approval of the reports prior to submission, and 4 reports did not have proper segregation of duties as related to the preparation and submission of the reports. Cause: For the late reports, department management did not monitor and ensure that the reports were submitted in a timely manner due to other emergency events at the County taking priority. For the reports with lack of review support, management did not maintain supporting documentation of the review performed on the reports prior to submission. Lastly, for the reports without proper segregation of duties, Harris County did not design or implement a segregation of duties control to ensure separate preparer and reviewer. Effect: Failure to review and approve the reports prior to submission to the grantor, late submission of the reports, and lack of segregation of duties increases the risk of submitting an inaccurate report and may result in the early termination of the award, reimbursement of award funds, and cessation of future funding. Recommendation: Management should establish detailed and precise controls to ensure timely reviews, clear identification of preparers and reviewers, and retain evidence of such reviews to ensure compliance with grant requirements. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Richard Williams, Deputy Chief Financial Officer of Harris County Public Health Danielle Calhoun, Associate Director of Harris County Public Health Allison Hare, Director of Public Health Emergency Preparedness Beatrice Best, Lead Grant Program Supervisor of Harris County Public Health
Noncompliance Finding and Significant Deficiency – Reporting Criteria: 2CFR 200.303 establishes that grant recipients should establish, document, and maintain effective internal control over federal awards, including controls over reviews of reports and compliance with reporting requirements. 2 CFR 200.239(c) establishes that grant recipients should submit performance reports timely. Condition: During our testing, D&T inspected 16 programmatic reports whereby there should have been appropriate levels of review and compliance with submission requirements. Two reports were submitted to the granting agency late, 3 reports did not have any evidence of review and approval of the reports prior to submission, and 4 reports did not have proper segregation of duties as related to the preparation and submission of the reports. Cause: For the late reports, department management did not monitor and ensure that the reports were submitted in a timely manner due to other emergency events at the County taking priority. For the reports with lack of review support, management did not maintain supporting documentation of the review performed on the reports prior to submission. Lastly, for the reports without proper segregation of duties, Harris County did not design or implement a segregation of duties control to ensure separate preparer and reviewer. Effect: Failure to review and approve the reports prior to submission to the grantor, late submission of the reports, and lack of segregation of duties increases the risk of submitting an inaccurate report and may result in the early termination of the award, reimbursement of award funds, and cessation of future funding. Recommendation: Management should establish detailed and precise controls to ensure timely reviews, clear identification of preparers and reviewers, and retain evidence of such reviews to ensure compliance with grant requirements. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Richard Williams, Deputy Chief Financial Officer of Harris County Public Health Danielle Calhoun, Associate Director of Harris County Public Health Allison Hare, Director of Public Health Emergency Preparedness Beatrice Best, Lead Grant Program Supervisor of Harris County Public Health
Noncompliance Finding and Significant Deficiency – Reporting Criteria: 2CFR 200.303 establishes that grant recipients should establish, document, and maintain effective internal control over federal awards, including controls over reviews of reports and compliance with reporting requirements. 2 CFR 200.239(c) establishes that grant recipients should submit performance reports timely. Condition: During our testing, D&T inspected 16 programmatic reports whereby there should have been appropriate levels of review and compliance with submission requirements. Two reports were submitted to the granting agency late, 3 reports did not have any evidence of review and approval of the reports prior to submission, and 4 reports did not have proper segregation of duties as related to the preparation and submission of the reports. Cause: For the late reports, department management did not monitor and ensure that the reports were submitted in a timely manner due to other emergency events at the County taking priority. For the reports with lack of review support, management did not maintain supporting documentation of the review performed on the reports prior to submission. Lastly, for the reports without proper segregation of duties, Harris County did not design or implement a segregation of duties control to ensure separate preparer and reviewer. Effect: Failure to review and approve the reports prior to submission to the grantor, late submission of the reports, and lack of segregation of duties increases the risk of submitting an inaccurate report and may result in the early termination of the award, reimbursement of award funds, and cessation of future funding. Recommendation: Management should establish detailed and precise controls to ensure timely reviews, clear identification of preparers and reviewers, and retain evidence of such reviews to ensure compliance with grant requirements. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Richard Williams, Deputy Chief Financial Officer of Harris County Public Health Danielle Calhoun, Associate Director of Harris County Public Health Allison Hare, Director of Public Health Emergency Preparedness Beatrice Best, Lead Grant Program Supervisor of Harris County Public Health
Noncompliance Finding and Significant Deficiency – Reporting Criteria: 2CFR 200.303 establishes that grant recipients should establish, document, and maintain effective internal control over federal awards, including controls over reviews of reports and compliance with reporting requirements. 2 CFR 200.239(c) establishes that grant recipients should submit performance reports timely. Condition: During our testing, D&T inspected 16 programmatic reports whereby there should have been appropriate levels of review and compliance with submission requirements. Two reports were submitted to the granting agency late, 3 reports did not have any evidence of review and approval of the reports prior to submission, and 4 reports did not have proper segregation of duties as related to the preparation and submission of the reports. Cause: For the late reports, department management did not monitor and ensure that the reports were submitted in a timely manner due to other emergency events at the County taking priority. For the reports with lack of review support, management did not maintain supporting documentation of the review performed on the reports prior to submission. Lastly, for the reports without proper segregation of duties, Harris County did not design or implement a segregation of duties control to ensure separate preparer and reviewer. Effect: Failure to review and approve the reports prior to submission to the grantor, late submission of the reports, and lack of segregation of duties increases the risk of submitting an inaccurate report and may result in the early termination of the award, reimbursement of award funds, and cessation of future funding. Recommendation: Management should establish detailed and precise controls to ensure timely reviews, clear identification of preparers and reviewers, and retain evidence of such reviews to ensure compliance with grant requirements. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Richard Williams, Deputy Chief Financial Officer of Harris County Public Health Danielle Calhoun, Associate Director of Harris County Public Health Allison Hare, Director of Public Health Emergency Preparedness Beatrice Best, Lead Grant Program Supervisor of Harris County Public Health
Noncompliance Finding and Significant Deficiency – Reporting Criteria: 2CFR 200.303 establishes that grant recipients should establish, document, and maintain effective internal control over federal awards, including controls over reviews of reports and compliance with reporting requirements. 2 CFR 200.239(c) establishes that grant recipients should submit performance reports timely. Condition: During our testing, D&T inspected 16 programmatic reports whereby there should have been appropriate levels of review and compliance with submission requirements. Two reports were submitted to the granting agency late, 3 reports did not have any evidence of review and approval of the reports prior to submission, and 4 reports did not have proper segregation of duties as related to the preparation and submission of the reports. Cause: For the late reports, department management did not monitor and ensure that the reports were submitted in a timely manner due to other emergency events at the County taking priority. For the reports with lack of review support, management did not maintain supporting documentation of the review performed on the reports prior to submission. Lastly, for the reports without proper segregation of duties, Harris County did not design or implement a segregation of duties control to ensure separate preparer and reviewer. Effect: Failure to review and approve the reports prior to submission to the grantor, late submission of the reports, and lack of segregation of duties increases the risk of submitting an inaccurate report and may result in the early termination of the award, reimbursement of award funds, and cessation of future funding. Recommendation: Management should establish detailed and precise controls to ensure timely reviews, clear identification of preparers and reviewers, and retain evidence of such reviews to ensure compliance with grant requirements. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Richard Williams, Deputy Chief Financial Officer of Harris County Public Health Danielle Calhoun, Associate Director of Harris County Public Health Allison Hare, Director of Public Health Emergency Preparedness Beatrice Best, Lead Grant Program Supervisor of Harris County Public Health
Noncompliance Finding and Significant Deficiency – Reporting Criteria: 2CFR 200.303 establishes that grant recipients should establish, document, and maintain effective internal control over federal awards, including controls over reviews of reports and compliance with reporting requirements. 2 CFR 200.239(c) establishes that grant recipients should submit performance reports timely. Condition: During our testing, D&T inspected 16 programmatic reports whereby there should have been appropriate levels of review and compliance with submission requirements. Two reports were submitted to the granting agency late, 3 reports did not have any evidence of review and approval of the reports prior to submission, and 4 reports did not have proper segregation of duties as related to the preparation and submission of the reports. Cause: For the late reports, department management did not monitor and ensure that the reports were submitted in a timely manner due to other emergency events at the County taking priority. For the reports with lack of review support, management did not maintain supporting documentation of the review performed on the reports prior to submission. Lastly, for the reports without proper segregation of duties, Harris County did not design or implement a segregation of duties control to ensure separate preparer and reviewer. Effect: Failure to review and approve the reports prior to submission to the grantor, late submission of the reports, and lack of segregation of duties increases the risk of submitting an inaccurate report and may result in the early termination of the award, reimbursement of award funds, and cessation of future funding. Recommendation: Management should establish detailed and precise controls to ensure timely reviews, clear identification of preparers and reviewers, and retain evidence of such reviews to ensure compliance with grant requirements. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Richard Williams, Deputy Chief Financial Officer of Harris County Public Health Danielle Calhoun, Associate Director of Harris County Public Health Allison Hare, Director of Public Health Emergency Preparedness Beatrice Best, Lead Grant Program Supervisor of Harris County Public Health
Program title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds COVID-19 Airport Improvement Program Assistance Listing Numbers: 21.027 20.106 Federal Award ID Number: SLFRP0894, 23PLN17 3-12-0145-012-2023, 3-12-0145-017-2021 Name of Federal Agency: United States Department of Treasury - Award 23PLN17 Passed through the Florida Department of Environmental Protection; Federal Aviation Authority Funding: 2024 Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Reports should be subject to independent review to verify completeness, validity and timeliness of submission. The grant agreements required various performance/reimbursement/financial reports. The reports were not reviewed prior to submission to granting agency. A Quarterly report required for the Federal Aviation Authority was not submitted within the 30 days after quarter close. Condition: During the audit, it was identified that required reports were not reviewed prior to submission. Reports were submitted, but there was no documented evidence of thorough review or oversight, leading to concerns regarding the accuracy, completeness, and compliance of the reports. During the audit, it Report 5370 was submitted late. The required due date was within 30 days of quarter close. The report was submitted twenty-two days after due date. Cause: The City was unaware of the requirement that reports be reviewed by a person other than the preparer prior to submission. The City received the invoices for the quarterly reports after the due date, causing a delay in submitting the report. Effect: The absence of regular reviews increases the risk of errors, omissions, or non-compliance with regulatory requirements. This oversight can lead to financial discrepancies, inaccurate reporting and matching amounts, and potential legal or reputational risks. Additionally, failure to review reports may delay the identification of operational issues or inefficiencies. The late submission may cause disruptions in compliance with regulatory timelines, potentially lead to penalties or loss of funding. Questioned Costs: None Perspective: Two of the grants that required reports, both did not have any reports reviewed. CRI tested three of the six required reports. Only one was submitted late. Recommendation: Management should implement a formalized process for reviewing all required reports prior to submission. Management’s Response: Management agrees that all financial data would potentially be more accurate if reviewed by an additional qualified person prior to use. However, limited staff has prevented this from always being practical. In the future, management will seek ways to add more controls to all of our processes, including reviews, to ensure more accurate and reliable data is submitted.
Program title: COVID-19 Coronavirus State and Local Fiscal Recover Funds Assistance Listing Numbers: 21.027 Federal Award ID Number: SLFRP0894, 23PLN17 Name of Federal Agency: United States Department of Treasury - Award 23PLN17 Passed through the Florida Department of Environmental Protection; Funding: 2024 Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Vendors should be checked for suspension and debarment prior to services being performed. Condition: During the audit, it was determined that 2 of the 2 vendors selected for projects were not screened against the federal suspension and debarment list prior to award. The vendor was not verified against the System for Award Management (SAM) or other relevant databases to ensure they were not excluded from doing business with the government, as required by federal regulations. Cause: The City was in the process of hiring a new procurement manager and relied on piggybacking on county contracts when selecting vendors. Effect: The failure to check the vendor against suspension and debarment lists exposes the City to the risk of engaging with vendors who may be ineligible to perform work under federally funded programs. This non-compliance could lead to potential financial penalties, legal consequences, and reputational damage, as well as the risk of working with unqualified or non-compliant vendors. Questioned Costs: None Perspective: One hundred percent of the population (2 vendors) was selected for testing. Both vendors were not checked for suspension and debarment. Recommendation: Management should implement a formalized process for checking all vendors prior to work being started on the project. Management’s Response: In January 2024 a Procurement Manager was hired. Procedures were added to ensure that the City will be in compliance with the 2 CFR 200.303 in the future.
Program title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds COVID-19 Airport Improvement Program Assistance Listing Numbers: 21.027 20.106 Federal Award ID Number: SLFRP0894, 23PLN17 3-12-0145-012-2023, 3-12-0145-017-2021 Name of Federal Agency: United States Department of Treasury - Award 23PLN17 Passed through the Florida Department of Environmental Protection; Federal Aviation Authority Funding: 2024 Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Reports should be subject to independent review to verify completeness, validity and timeliness of submission. The grant agreements required various performance/reimbursement/financial reports. The reports were not reviewed prior to submission to granting agency. A Quarterly report required for the Federal Aviation Authority was not submitted within the 30 days after quarter close. Condition: During the audit, it was identified that required reports were not reviewed prior to submission. Reports were submitted, but there was no documented evidence of thorough review or oversight, leading to concerns regarding the accuracy, completeness, and compliance of the reports. During the audit, it Report 5370 was submitted late. The required due date was within 30 days of quarter close. The report was submitted twenty-two days after due date. Cause: The City was unaware of the requirement that reports be reviewed by a person other than the preparer prior to submission. The City received the invoices for the quarterly reports after the due date, causing a delay in submitting the report. Effect: The absence of regular reviews increases the risk of errors, omissions, or non-compliance with regulatory requirements. This oversight can lead to financial discrepancies, inaccurate reporting and matching amounts, and potential legal or reputational risks. Additionally, failure to review reports may delay the identification of operational issues or inefficiencies. The late submission may cause disruptions in compliance with regulatory timelines, potentially lead to penalties or loss of funding. Questioned Costs: None Perspective: Two of the grants that required reports, both did not have any reports reviewed. CRI tested three of the six required reports. Only one was submitted late. Recommendation: Management should implement a formalized process for reviewing all required reports prior to submission. Management’s Response: Management agrees that all financial data would potentially be more accurate if reviewed by an additional qualified person prior to use. However, limited staff has prevented this from always being practical. In the future, management will seek ways to add more controls to all of our processes, including reviews, to ensure more accurate and reliable data is submitted.
Program title: COVID-19 Coronavirus State and Local Fiscal Recover Funds Assistance Listing Numbers: 21.027 Federal Award ID Number: SLFRP0894, 23PLN17 Name of Federal Agency: United States Department of Treasury - Award 23PLN17 Passed through the Florida Department of Environmental Protection; Funding: 2024 Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Vendors should be checked for suspension and debarment prior to services being performed. Condition: During the audit, it was determined that 2 of the 2 vendors selected for projects were not screened against the federal suspension and debarment list prior to award. The vendor was not verified against the System for Award Management (SAM) or other relevant databases to ensure they were not excluded from doing business with the government, as required by federal regulations. Cause: The City was in the process of hiring a new procurement manager and relied on piggybacking on county contracts when selecting vendors. Effect: The failure to check the vendor against suspension and debarment lists exposes the City to the risk of engaging with vendors who may be ineligible to perform work under federally funded programs. This non-compliance could lead to potential financial penalties, legal consequences, and reputational damage, as well as the risk of working with unqualified or non-compliant vendors. Questioned Costs: None Perspective: One hundred percent of the population (2 vendors) was selected for testing. Both vendors were not checked for suspension and debarment. Recommendation: Management should implement a formalized process for checking all vendors prior to work being started on the project. Management’s Response: In January 2024 a Procurement Manager was hired. Procedures were added to ensure that the City will be in compliance with the 2 CFR 200.303 in the future.
Program title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds COVID-19 Airport Improvement Program Assistance Listing Numbers: 21.027 20.106 Federal Award ID Number: SLFRP0894, 23PLN17 3-12-0145-012-2023, 3-12-0145-017-2021 Name of Federal Agency: United States Department of Treasury - Award 23PLN17 Passed through the Florida Department of Environmental Protection; Federal Aviation Authority Funding: 2024 Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Reports should be subject to independent review to verify completeness, validity and timeliness of submission. The grant agreements required various performance/reimbursement/financial reports. The reports were not reviewed prior to submission to granting agency. A Quarterly report required for the Federal Aviation Authority was not submitted within the 30 days after quarter close. Condition: During the audit, it was identified that required reports were not reviewed prior to submission. Reports were submitted, but there was no documented evidence of thorough review or oversight, leading to concerns regarding the accuracy, completeness, and compliance of the reports. During the audit, it Report 5370 was submitted late. The required due date was within 30 days of quarter close. The report was submitted twenty-two days after due date. Cause: The City was unaware of the requirement that reports be reviewed by a person other than the preparer prior to submission. The City received the invoices for the quarterly reports after the due date, causing a delay in submitting the report. Effect: The absence of regular reviews increases the risk of errors, omissions, or non-compliance with regulatory requirements. This oversight can lead to financial discrepancies, inaccurate reporting and matching amounts, and potential legal or reputational risks. Additionally, failure to review reports may delay the identification of operational issues or inefficiencies. The late submission may cause disruptions in compliance with regulatory timelines, potentially lead to penalties or loss of funding. Questioned Costs: None Perspective: Two of the grants that required reports, both did not have any reports reviewed. CRI tested three of the six required reports. Only one was submitted late. Recommendation: Management should implement a formalized process for reviewing all required reports prior to submission. Management’s Response: Management agrees that all financial data would potentially be more accurate if reviewed by an additional qualified person prior to use. However, limited staff has prevented this from always being practical. In the future, management will seek ways to add more controls to all of our processes, including reviews, to ensure more accurate and reliable data is submitted.
Program title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds COVID-19 Airport Improvement Program Assistance Listing Numbers: 21.027 20.106 Federal Award ID Number: SLFRP0894, 23PLN17 3-12-0145-012-2023, 3-12-0145-017-2021 Name of Federal Agency: United States Department of Treasury - Award 23PLN17 Passed through the Florida Department of Environmental Protection; Federal Aviation Authority Funding: 2024 Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Reports should be subject to independent review to verify completeness, validity and timeliness of submission. The grant agreements required various performance/reimbursement/financial reports. The reports were not reviewed prior to submission to granting agency. A Quarterly report required for the Federal Aviation Authority was not submitted within the 30 days after quarter close. Condition: During the audit, it was identified that required reports were not reviewed prior to submission. Reports were submitted, but there was no documented evidence of thorough review or oversight, leading to concerns regarding the accuracy, completeness, and compliance of the reports. During the audit, it Report 5370 was submitted late. The required due date was within 30 days of quarter close. The report was submitted twenty-two days after due date. Cause: The City was unaware of the requirement that reports be reviewed by a person other than the preparer prior to submission. The City received the invoices for the quarterly reports after the due date, causing a delay in submitting the report. Effect: The absence of regular reviews increases the risk of errors, omissions, or non-compliance with regulatory requirements. This oversight can lead to financial discrepancies, inaccurate reporting and matching amounts, and potential legal or reputational risks. Additionally, failure to review reports may delay the identification of operational issues or inefficiencies. The late submission may cause disruptions in compliance with regulatory timelines, potentially lead to penalties or loss of funding. Questioned Costs: None Perspective: Two of the grants that required reports, both did not have any reports reviewed. CRI tested three of the six required reports. Only one was submitted late. Recommendation: Management should implement a formalized process for reviewing all required reports prior to submission. Management’s Response: Management agrees that all financial data would potentially be more accurate if reviewed by an additional qualified person prior to use. However, limited staff has prevented this from always being practical. In the future, management will seek ways to add more controls to all of our processes, including reviews, to ensure more accurate and reliable data is submitted.
Department of Agriculture Federal Financial Assistance Listing #10.766 Special Tests and Provisions Material Weakness in Internal Control over Compliance and Noncompliance Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The loan resolution security agreements state the Organization must set aside a reserve amount which may be established as a bookkeeping account or as a separate bank account. Funds may be deposited in institutions insured by state and federal government or invested in marketable securities backed by the full faith and credit of the United States. Condition: The funds that represented the debt service reserve fund were commingled with an existing operating cash account. Cause: The Hospital did not maintain a separate bank account or general ledger account for the debt service reserve fund. Effect: The debt service reserve funds were commingled with other operating funds within an operating cash account. Questioned Costs: None reported. Context: Sampling was not used. Recommendation: We recommend that management maintain a separate bank account or general ledger account for the debt service reserve fund. Views of Responsible Officials: Management agrees with the finding.
Item 2024-002 – Suspension and Debarment U.S. Department of Treasury COVID-19 Coronavirus State and Local Fiscal Recovery Funds Listing #21.027 Year Ended September 30, 2024 Criteria – 2 CFR 200.303 requires the non‐Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” Non‐Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition – Adequate controls were not in place to provide for proper review of covered transactions for suspension and debarment. Covered transactions, over $25,000 paid with grant funding were not reviewed for suspension and debarment. Cause – The City lacked sufficient controls to ensure evidence of compliance with suspension and debarment. Questioned Costs – None noted Effect – Failure to properly verify that a potential vendor has not been suspended or debarred could result in unallowable expenditures and disallowed costs. Recommendation – We recommend that controls should be put into place to better monitor and document the compliance of vendors for suspension and debarment. Management’s Response – The City will implement additional controls to ensure there is evidence of review of covered transactions over $25,000 for suspension and debarment prior to payment. City’s Financial Officer will be responsible for the corrective action and anticipates completion of corrective action will be taken before September 30, 2025.
2024-001 – Child Support Services - Unallowable Costs Finding Type: Significant deficiency in internal controls and immaterial noncompliance Criteria: Per 2 CFR § 200.303 (Internal Controls), non-federal entities must establish and maintain effective internal controls over federal awards that provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of the award. Additionally, 2 CFR § 200.430 (Compensation—Personal Services) requires that payroll costs charged to federal awards must be based on records that accurately reflect the work performed and be supported by adequate documentation. Condition/Finding: During our audit of Manistee County’s Child Support Services federal grant expenditures, it was determined that the County lacked effectively operating controls to ensure that salary and wage expenses charged to the Child Support Services program were allowable and properly allocated. Cause: The County’s internal controls were not adequately designed or implemented to ensure compliance with federal grant requirements. Effect: As a result, the County received an overpayment of federal funds of $5,528.41 during FY 2024. Recommendation: We recommend that the County take actions to strengthen internal controls over payroll expenditures related to federal grants to ensure compliance with federal cost principles and proper expense allocation. View of Responsible Officials (Corrective Action): See corrective action plan.
2024-001 – Child Support Services - Unallowable Costs Finding Type: Significant deficiency in internal controls and immaterial noncompliance Criteria: Per 2 CFR § 200.303 (Internal Controls), non-federal entities must establish and maintain effective internal controls over federal awards that provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of the award. Additionally, 2 CFR § 200.430 (Compensation—Personal Services) requires that payroll costs charged to federal awards must be based on records that accurately reflect the work performed and be supported by adequate documentation. Condition/Finding: During our audit of Manistee County’s Child Support Services federal grant expenditures, it was determined that the County lacked effectively operating controls to ensure that salary and wage expenses charged to the Child Support Services program were allowable and properly allocated. Cause: The County’s internal controls were not adequately designed or implemented to ensure compliance with federal grant requirements. Effect: As a result, the County received an overpayment of federal funds of $5,528.41 during FY 2024. Recommendation: We recommend that the County take actions to strengthen internal controls over payroll expenditures related to federal grants to ensure compliance with federal cost principles and proper expense allocation. View of Responsible Officials (Corrective Action): See corrective action plan.
Criteria or Requirement 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include establishing procedures to ensure timely and accurate reporting of financial information required by the agreement with the United States Postal Service or obtaining written approval of any extension of reporting deadlines. Condition Found, including Perspective The Organization has not established adequate internal control procedures to ensure the timely submission of the Financial Report, Contribution Reports, and Quality Report (collectively the Annual Reports) to the United States Postal Service (USPS) for the National Postal Museum (NPM) project. Prior to the June 30, 2024 reporting deadline, the Organization notified USPS the Annual Reports would be submitted late as a result of employee turnover, and USPS acknowledged the delay. A formal extension of the deadline was not granted. The Organization eventually submitted its Annual Reports to the USPS on February 12, 2025 (227 days late), for the June 30, 2024 reporting deadline. Possible Cause and Effect The Organization experienced turnover within the NPM project. Specifically, the individual responsible for preparing the Annual Reports left the Organization in fiscal year 2023 and it took time for the successor to learn the reporting process resulting in delayed reporting. Questioned Costs None identified. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No Recommendation We recommend the Organization appropriately identify resources needed to fulfill the reporting requirements under the NPM agreement to help ensure the Annual Reports are submitted to the USPS within the required deadlines. Additionally, the Organization should establish a comprehensive list of NPM requirements and should establish procedures to cross train staff to perform required responsibilities applicable to the NPM Project. Views of Responsible Officials The Smithsonian agrees with the finding. The Smithsonian would like to add that the reports were delivered to the sponsor and that the sponsor was satisfied with them. Furthermore, the sponsor has provided written acknowledgment that they were “verbally kept up to date” by the National Postal Museum (NPM) regarding this potential delay. Moving forward, NPM will strengthen senior management oversight of report delivery, review due dates more rigorously, and enhance internal controls to ensure timely submission. Any potential delays will be confirmed in writing to the sponsor ahead of the due date, and compliance updates will be provided by NPM senior management to the sponsor on a regular basis. Additionally, NPM will establish procedures to cross train staff to perform required responsibilities applicable to the NPM Project.
Major Program: Community Service Block Grant AL #93.569 Compliance Requirement: Eligibility Questioned Costs: None Type of Finding: Significant Deficiency in Internal Control over Compliance of Major Programs Criteria: The Community Action Agency must establish and maintain effective internal control over federal awards that provides reasonable assurance of compliance with applicable federal statutes, regulations, and the terms and conditions of the award, in accordance with 2 CFR §200.303. For the eligibility compliance requirement, documentation must clearly demonstrate that eligibility was determined prior to the provision of benefits, and that all required approvals were contemporaneously documented. Condition: During eligibility testing, it was identified that one intake form out of a sample of 40 exhibited a discrepancy in the timing of documentation completion and staff review. Specifically, for a client who received food pantry services on January 25, 2024, the client received and signed the Food Pantry Service Sheet on that same day, confirming eligibility determination. However, the CAASTLC staff member did not sign the form until January 31, 2024, several days after the client had received services. The MIS intake report reflects a date of February 2, 2024, which corresponds to when the data was entered into the system, rather than the date eligibility was actually determine. Cause: The procedures in place prioritized maintaining traffic flow during drive-through food pantry operations over contemporaneous documentation practices. As a result, the staff review and signature confirming eligibility were delayed and not completed on the date of service. Effect: Although eligibility was assessed and determined prior to the provision of services, the absence of timely staff signatures weakens the audit trail. This increases the risk that services may be provided without proper approval or that documentation may not adequately support compliance with eligibility requirements during an audit or program review. Recommendation: The Organization should strengthen internal controls and provide additional staff training to ensure all eligibility documentation—including staff review and signatures—is completed contemporaneously with client service. Where operational constraints exist, the Organization should consider implementing procedures to document eligibility determinations in real-time, or adopt digital tools to capture staff approval at the point of intake. View of Responsible Officials: See Corrective Action Plan.
U.S. Department of State: Bureau of Population and Refugees and Migration: Oversees Refugee Assistance Programs for Africa: Advancing access to integrated life-saving assistance and protection services to promote selfreliance and resilience for refugees and host communities in Uganda (ALN 19.517, award number SPRMCO23CA0106) U.S. Agency for International Development: USAID Foreign Assistance for Programs Oversees: Holistic prevention and response services to support people affected by forced displacement to restore and rebuild their lives (ALN 98.001, award number 720BHA22GR00304) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Noncompliance and Significant Deficiency Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards for HHS Awards, section 75.2 defines Subaward as an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. Further, 45 CFR 75.2 defines Subrecipient as a non-federal entity that receives a subaward from a passthrough entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other federal awards directly from a federal awarding agency. Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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 following subaward data elements to be reported include the following: • Subawardee Name • Subawardee Unique Entity Identifier • Amount of Subaward • Subaward Obligation/Action Date • Date of Report Submission • Subaward Number • Subaward Project Description • Subawardee Names and Compensation of Highly Compensated Officers, if applicable The information is required to be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For ALN 19.517, there were 3 new or amended subawardee agreements entered into during fiscal year 2024. We selected all three of these agreements for test work and noted that while all the key data elements were accurately submitted, the information for all three agreements was not submitted timely. All of the agreements were entered into on October 1, 2023 and the information was submitted in January 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions: Transactions Tested - 3 Subaward not reported - 0 Report not timely - 3 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $957,943 Subaward not reported - $0 Report not timely - $957,943 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 For ALN 98.001, there were 23 new or amended subawardee agreements entered into during fiscal year 2024. We selected four for test work and noted that while all the key data elements were accurately submitted, the information for two of these agreements was not submitted timely. These two agreements were entered into on January 1, 2024 and March 1, 2024 and the information was not submitted until November of 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for certain subawards on a timely basis. We noted the following exceptions: Transactions Tested - 4 Subaward not reported - 0 Report not timely - 2 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $1,349,750 Subaward not reported - $0 Report not timely - $112,617 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 Cause: Responsible staff encountered challenges accessing SAM.gov due to credential errors, which resulted in delays in submitting or updating subrecipient details in a timely manner. Effect: Delayed reporting can lead to reduced transparency, hindering public access to information about how federal funds are being used. Questioned Costs: None. Recommendation: IRC should continue to communicate to all field office personnel responsible for FFATA submissions the importance of timely reporting. We recommend adding another level of review from headquarters to ensure reporting is taking place once a subawardee agreement is finalized. Views of Responsible Officials: Management agrees with this finding and will take the necessary actions to ensure its FFATA reporting is more timely.
U.S. Department of State: Bureau of Population and Refugees and Migration: Oversees Refugee Assistance Programs for Africa: Advancing access to integrated life-saving assistance and protection services to promote selfreliance and resilience for refugees and host communities in Uganda (ALN 19.517, award number SPRMCO23CA0106) U.S. Agency for International Development: USAID Foreign Assistance for Programs Oversees: Holistic prevention and response services to support people affected by forced displacement to restore and rebuild their lives (ALN 98.001, award number 720BHA22GR00304) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Noncompliance and Significant Deficiency Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards for HHS Awards, section 75.2 defines Subaward as an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. Further, 45 CFR 75.2 defines Subrecipient as a non-federal entity that receives a subaward from a passthrough entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other federal awards directly from a federal awarding agency. Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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 following subaward data elements to be reported include the following: • Subawardee Name • Subawardee Unique Entity Identifier • Amount of Subaward • Subaward Obligation/Action Date • Date of Report Submission • Subaward Number • Subaward Project Description • Subawardee Names and Compensation of Highly Compensated Officers, if applicable The information is required to be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For ALN 19.517, there were 3 new or amended subawardee agreements entered into during fiscal year 2024. We selected all three of these agreements for test work and noted that while all the key data elements were accurately submitted, the information for all three agreements was not submitted timely. All of the agreements were entered into on October 1, 2023 and the information was submitted in January 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions: Transactions Tested - 3 Subaward not reported - 0 Report not timely - 3 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $957,943 Subaward not reported - $0 Report not timely - $957,943 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 For ALN 98.001, there were 23 new or amended subawardee agreements entered into during fiscal year 2024. We selected four for test work and noted that while all the key data elements were accurately submitted, the information for two of these agreements was not submitted timely. These two agreements were entered into on January 1, 2024 and March 1, 2024 and the information was not submitted until November of 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for certain subawards on a timely basis. We noted the following exceptions: Transactions Tested - 4 Subaward not reported - 0 Report not timely - 2 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $1,349,750 Subaward not reported - $0 Report not timely - $112,617 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 Cause: Responsible staff encountered challenges accessing SAM.gov due to credential errors, which resulted in delays in submitting or updating subrecipient details in a timely manner. Effect: Delayed reporting can lead to reduced transparency, hindering public access to information about how federal funds are being used. Questioned Costs: None. Recommendation: IRC should continue to communicate to all field office personnel responsible for FFATA submissions the importance of timely reporting. We recommend adding another level of review from headquarters to ensure reporting is taking place once a subawardee agreement is finalized. Views of Responsible Officials: Management agrees with this finding and will take the necessary actions to ensure its FFATA reporting is more timely.
MW 2024‐001 REPORTING United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Criteria: Per 2 CFR 200.303, non‐Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with the Uniform Guidance and the terms and conditions outlined by the Environmental Protection Agency. EPA recipients must submit the Federal Financial Report (SF‐425) at least annually. EPA recipients must submit the SF‐425 no later than 90 calendar days for annual reports. Final reports are due no later than 120 calendar days after the end date of the period of performance of the award. Condition: The Federal Financial Report Standard Form 425 was submitted late to the Environmental Protection Agency on March 10, 2025. Cause: The Environmental Protection Agency had informed the Council that these reports were only due at closeout of the grant; therefore, the Council did not submit these reports. However, the Office of Inspector General (OIG) stated that this was not the correct procedure. As a result of the OIG's EPA audit, the Council filed these reports on March 10, 2025 with the EPA to be in compliance. Effect: Potential for unintended errors to occur without being immediately identified and corrected. The Council was not in compliance with the Uniform Guidance and the National Estuary Program. Questioned Costs: None. Perspective: All of the reports identified above were not reviewed. Recommendation: The Chief Operating Officer should obtain in writing any adjustments or clarifications to the grant awards to ensure the requested reports are prepared and reviewed. Management Response: EPA has never requested the SF425 (Federal Financial Reporting Form) from year’s prior and we were told verbally that we were only required to submit them at grant closeout. During a current EPA OIG audit, we were informed that the procedural process we were following was incorrect and that yearly reports were required to be submitted. To bring the IRL Council back into compliance with all federal awards, the Chief Operating Officer completed the FY 2024 forms and submitted them to EPA on March 10, 2025.
MW 2024‐001 REPORTING United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Criteria: Per 2 CFR 200.303, non‐Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with the Uniform Guidance and the terms and conditions outlined by the Environmental Protection Agency. EPA recipients must submit the Federal Financial Report (SF‐425) at least annually. EPA recipients must submit the SF‐425 no later than 90 calendar days for annual reports. Final reports are due no later than 120 calendar days after the end date of the period of performance of the award. Condition: The Federal Financial Report Standard Form 425 was submitted late to the Environmental Protection Agency on March 10, 2025. Cause: The Environmental Protection Agency had informed the Council that these reports were only due at closeout of the grant; therefore, the Council did not submit these reports. However, the Office of Inspector General (OIG) stated that this was not the correct procedure. As a result of the OIG's EPA audit, the Council filed these reports on March 10, 2025 with the EPA to be in compliance. Effect: Potential for unintended errors to occur without being immediately identified and corrected. The Council was not in compliance with the Uniform Guidance and the National Estuary Program. Questioned Costs: None. Perspective: All of the reports identified above were not reviewed. Recommendation: The Chief Operating Officer should obtain in writing any adjustments or clarifications to the grant awards to ensure the requested reports are prepared and reviewed. Management Response: EPA has never requested the SF425 (Federal Financial Reporting Form) from year’s prior and we were told verbally that we were only required to submit them at grant closeout. During a current EPA OIG audit, we were informed that the procedural process we were following was incorrect and that yearly reports were required to be submitted. To bring the IRL Council back into compliance with all federal awards, the Chief Operating Officer completed the FY 2024 forms and submitted them to EPA on March 10, 2025.
MW 2024‐001 REPORTING United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Criteria: Per 2 CFR 200.303, non‐Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with the Uniform Guidance and the terms and conditions outlined by the Environmental Protection Agency. EPA recipients must submit the Federal Financial Report (SF‐425) at least annually. EPA recipients must submit the SF‐425 no later than 90 calendar days for annual reports. Final reports are due no later than 120 calendar days after the end date of the period of performance of the award. Condition: The Federal Financial Report Standard Form 425 was submitted late to the Environmental Protection Agency on March 10, 2025. Cause: The Environmental Protection Agency had informed the Council that these reports were only due at closeout of the grant; therefore, the Council did not submit these reports. However, the Office of Inspector General (OIG) stated that this was not the correct procedure. As a result of the OIG's EPA audit, the Council filed these reports on March 10, 2025 with the EPA to be in compliance. Effect: Potential for unintended errors to occur without being immediately identified and corrected. The Council was not in compliance with the Uniform Guidance and the National Estuary Program. Questioned Costs: None. Perspective: All of the reports identified above were not reviewed. Recommendation: The Chief Operating Officer should obtain in writing any adjustments or clarifications to the grant awards to ensure the requested reports are prepared and reviewed. Management Response: EPA has never requested the SF425 (Federal Financial Reporting Form) from year’s prior and we were told verbally that we were only required to submit them at grant closeout. During a current EPA OIG audit, we were informed that the procedural process we were following was incorrect and that yearly reports were required to be submitted. To bring the IRL Council back into compliance with all federal awards, the Chief Operating Officer completed the FY 2024 forms and submitted them to EPA on March 10, 2025.
SD 2024‐002 SUSPENSION AND DEBARMENT United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Repeat finding Criteria: 2 CFR 200.303 requires non‐federal entities to establish and maintain effective internal controls. Pursuant to 2 CFR section 180.300, the Council may not contract with or make subawards to parties that are identified as being suspended or debarred by the Federal Government. The Council must verify the parties’ eligibility to receive payment from a program funded by a Federal grant prior to entering a covered transaction (as defined in 2 CFR section 180.220). Condition: The Council did not have a process in place to verify that subrecipients and vendors for covered transactions were not suspended or debarred. Cause: Management was not aware of this procurement requirement. Effect: The Council could inadvertently enter a covered transaction with a suspended or debarred party, resulting in the disallowance of payments made to that party as eligible costs under the Federal program. Questioned Costs: None. Perspective: Many of the subawards made by the Council were to other local governments or universities, which are entities unlikely to be suspended or debarred. As part of our compliance testing, we tested a sample of subrecipients and vendors for suspension and debarment, noting no exceptions. Recommendation: We recommend the Council continue with the controls that were implemented in late 2024 to ensure the Council does not enter a subaward or other covered transaction with a party that is suspended, debarred or otherwise excluded from participating in federal awards. As the control was not in place for the majority of 2024, it is a repeat finding. Management Response: The IRL Council amended its Operating Procedures following the FY 2023 finding to include suspension and debarment procedures into procurement methods for activities that are federally funded. The IRL Council Chief Operating Officer, immediately checked all current vendors for compliance within SAM.gov and all new or amended agreements have since been checked in SAM.gov for compliance. As noted by Carr, Riggs, and Ingram there were no instances of exception in their testing. Due to the timing of the FY 2023 finding, FY 2024 would also be considered a finding regardless of any corrective action taken.
SD 2024‐002 SUSPENSION AND DEBARMENT United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Repeat finding Criteria: 2 CFR 200.303 requires non‐federal entities to establish and maintain effective internal controls. Pursuant to 2 CFR section 180.300, the Council may not contract with or make subawards to parties that are identified as being suspended or debarred by the Federal Government. The Council must verify the parties’ eligibility to receive payment from a program funded by a Federal grant prior to entering a covered transaction (as defined in 2 CFR section 180.220). Condition: The Council did not have a process in place to verify that subrecipients and vendors for covered transactions were not suspended or debarred. Cause: Management was not aware of this procurement requirement. Effect: The Council could inadvertently enter a covered transaction with a suspended or debarred party, resulting in the disallowance of payments made to that party as eligible costs under the Federal program. Questioned Costs: None. Perspective: Many of the subawards made by the Council were to other local governments or universities, which are entities unlikely to be suspended or debarred. As part of our compliance testing, we tested a sample of subrecipients and vendors for suspension and debarment, noting no exceptions. Recommendation: We recommend the Council continue with the controls that were implemented in late 2024 to ensure the Council does not enter a subaward or other covered transaction with a party that is suspended, debarred or otherwise excluded from participating in federal awards. As the control was not in place for the majority of 2024, it is a repeat finding. Management Response: The IRL Council amended its Operating Procedures following the FY 2023 finding to include suspension and debarment procedures into procurement methods for activities that are federally funded. The IRL Council Chief Operating Officer, immediately checked all current vendors for compliance within SAM.gov and all new or amended agreements have since been checked in SAM.gov for compliance. As noted by Carr, Riggs, and Ingram there were no instances of exception in their testing. Due to the timing of the FY 2023 finding, FY 2024 would also be considered a finding regardless of any corrective action taken.
SD 2024‐002 SUSPENSION AND DEBARMENT United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Repeat finding Criteria: 2 CFR 200.303 requires non‐federal entities to establish and maintain effective internal controls. Pursuant to 2 CFR section 180.300, the Council may not contract with or make subawards to parties that are identified as being suspended or debarred by the Federal Government. The Council must verify the parties’ eligibility to receive payment from a program funded by a Federal grant prior to entering a covered transaction (as defined in 2 CFR section 180.220). Condition: The Council did not have a process in place to verify that subrecipients and vendors for covered transactions were not suspended or debarred. Cause: Management was not aware of this procurement requirement. Effect: The Council could inadvertently enter a covered transaction with a suspended or debarred party, resulting in the disallowance of payments made to that party as eligible costs under the Federal program. Questioned Costs: None. Perspective: Many of the subawards made by the Council were to other local governments or universities, which are entities unlikely to be suspended or debarred. As part of our compliance testing, we tested a sample of subrecipients and vendors for suspension and debarment, noting no exceptions. Recommendation: We recommend the Council continue with the controls that were implemented in late 2024 to ensure the Council does not enter a subaward or other covered transaction with a party that is suspended, debarred or otherwise excluded from participating in federal awards. As the control was not in place for the majority of 2024, it is a repeat finding. Management Response: The IRL Council amended its Operating Procedures following the FY 2023 finding to include suspension and debarment procedures into procurement methods for activities that are federally funded. The IRL Council Chief Operating Officer, immediately checked all current vendors for compliance within SAM.gov and all new or amended agreements have since been checked in SAM.gov for compliance. As noted by Carr, Riggs, and Ingram there were no instances of exception in their testing. Due to the timing of the FY 2023 finding, FY 2024 would also be considered a finding regardless of any corrective action taken.
SD 2024‐003 SUBRECIPIENT MONITORING United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Repeat finding Criteria: 2 CFR 200.303 requires non‐federal entities to establish and maintain effective internal controls. The use of subrecipients in achieving the goals of the federal award requires the establishment of controls over the monitoring of subrecipients pursuant to 2 CFR section 200.331 and 200.332. This includes all requirements imposed by the pass‐through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award and any additional requirements that the pass‐through entity imposes on the subrecipient in order for the pass‐through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Condition: The Council did not have controls in place to obtain and review subrecipient single audit reports as a means to ensure the subrecipients are taking timely and appropriate action on deficiencies, if any, pertaining to the Federal award. Cause: The Council requested audits from it's subrecipients; however, if the most recent year was not yet available the prior fiscal year's audit was not requested to review for any deficiencies. Effect: Without the monitoring of the results of audits and on‐site reviews, the Council may not have sufficient information to evaluate the risks of noncompliance associated with a subrecipient. Questioned Costs: None. Perspective: The Council did perform monitoring activities related to the use of funds by subrecipients; however, not all controls required for subrecipient monitoring to comply with 2 CFR section 200.331 and 200.332 were fully implemented for the fiscal year under audit. For the 8 subrecipients sampled, audit reports were obtained for 4 subrecipients. Recommendation: If the most recent subrecipient audit report is not yet available, management should request the prior fiscal year if not already obtained. Management Response: The IRL Council put controls in place to be more effective at subrecipient monitoring following the FY 2023 finding which included the following actions: The IRL Council reviewed all projects and activities currently allocated and funded by federal sources to ensure the Uniform Guidance was in place within their respective agreements, and they were amended as needed. All new subrecipient agreements funded by federal sources were not executed until the respective federal award was in place and the Uniform Guidance language was included. The IRL Council did request audit reports from subrecipients and made statements on them, however for the ones who had not completed their FY 2024 audit, a prior year audit report was not immediately requested and statements for those subrecipients had not yet been made. The IRL Council will implement a control to request prior year Financial Statements/audit reports from subrecipients who have not yet completed their report for the year being requested during the Council’s monitoring.
SD 2024‐003 SUBRECIPIENT MONITORING United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Repeat finding Criteria: 2 CFR 200.303 requires non‐federal entities to establish and maintain effective internal controls. The use of subrecipients in achieving the goals of the federal award requires the establishment of controls over the monitoring of subrecipients pursuant to 2 CFR section 200.331 and 200.332. This includes all requirements imposed by the pass‐through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award and any additional requirements that the pass‐through entity imposes on the subrecipient in order for the pass‐through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Condition: The Council did not have controls in place to obtain and review subrecipient single audit reports as a means to ensure the subrecipients are taking timely and appropriate action on deficiencies, if any, pertaining to the Federal award. Cause: The Council requested audits from it's subrecipients; however, if the most recent year was not yet available the prior fiscal year's audit was not requested to review for any deficiencies. Effect: Without the monitoring of the results of audits and on‐site reviews, the Council may not have sufficient information to evaluate the risks of noncompliance associated with a subrecipient. Questioned Costs: None. Perspective: The Council did perform monitoring activities related to the use of funds by subrecipients; however, not all controls required for subrecipient monitoring to comply with 2 CFR section 200.331 and 200.332 were fully implemented for the fiscal year under audit. For the 8 subrecipients sampled, audit reports were obtained for 4 subrecipients. Recommendation: If the most recent subrecipient audit report is not yet available, management should request the prior fiscal year if not already obtained. Management Response: The IRL Council put controls in place to be more effective at subrecipient monitoring following the FY 2023 finding which included the following actions: The IRL Council reviewed all projects and activities currently allocated and funded by federal sources to ensure the Uniform Guidance was in place within their respective agreements, and they were amended as needed. All new subrecipient agreements funded by federal sources were not executed until the respective federal award was in place and the Uniform Guidance language was included. The IRL Council did request audit reports from subrecipients and made statements on them, however for the ones who had not completed their FY 2024 audit, a prior year audit report was not immediately requested and statements for those subrecipients had not yet been made. The IRL Council will implement a control to request prior year Financial Statements/audit reports from subrecipients who have not yet completed their report for the year being requested during the Council’s monitoring.
SD 2024‐003 SUBRECIPIENT MONITORING United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Repeat finding Criteria: 2 CFR 200.303 requires non‐federal entities to establish and maintain effective internal controls. The use of subrecipients in achieving the goals of the federal award requires the establishment of controls over the monitoring of subrecipients pursuant to 2 CFR section 200.331 and 200.332. This includes all requirements imposed by the pass‐through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award and any additional requirements that the pass‐through entity imposes on the subrecipient in order for the pass‐through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Condition: The Council did not have controls in place to obtain and review subrecipient single audit reports as a means to ensure the subrecipients are taking timely and appropriate action on deficiencies, if any, pertaining to the Federal award. Cause: The Council requested audits from it's subrecipients; however, if the most recent year was not yet available the prior fiscal year's audit was not requested to review for any deficiencies. Effect: Without the monitoring of the results of audits and on‐site reviews, the Council may not have sufficient information to evaluate the risks of noncompliance associated with a subrecipient. Questioned Costs: None. Perspective: The Council did perform monitoring activities related to the use of funds by subrecipients; however, not all controls required for subrecipient monitoring to comply with 2 CFR section 200.331 and 200.332 were fully implemented for the fiscal year under audit. For the 8 subrecipients sampled, audit reports were obtained for 4 subrecipients. Recommendation: If the most recent subrecipient audit report is not yet available, management should request the prior fiscal year if not already obtained. Management Response: The IRL Council put controls in place to be more effective at subrecipient monitoring following the FY 2023 finding which included the following actions: The IRL Council reviewed all projects and activities currently allocated and funded by federal sources to ensure the Uniform Guidance was in place within their respective agreements, and they were amended as needed. All new subrecipient agreements funded by federal sources were not executed until the respective federal award was in place and the Uniform Guidance language was included. The IRL Council did request audit reports from subrecipients and made statements on them, however for the ones who had not completed their FY 2024 audit, a prior year audit report was not immediately requested and statements for those subrecipients had not yet been made. The IRL Council will implement a control to request prior year Financial Statements/audit reports from subrecipients who have not yet completed their report for the year being requested during the Council’s monitoring.
Identification of the Federal Program - Meat and Poultry Intermediary Lending Program - Assistance Listing Number 10.382. Criteria - The criteria is based on the guidelines and regulations set forth by the funding agency, the United States Department of Ariculture and the Compliance and Reporting Guidance included in the grant agreements. According to these requirements, recipients must submit Federal financial reports 30 days after the close of the reporting period to ensure timely accounting of the use of USDA funds. 2 CFR 200.303, Internal Controls, requires that recipients establish and maintain effective internal control over Federal awards that provides reasonable assurance that the recipient is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Condition - There was a lack of monitoring and appropriate review by the Authority to ensure certain reports were prepared in a timely manner. Effect - There were three reporting periods during the fiscal year under audit. The reports for two reporting periods were not submitted timely. The semiannual reports were not submitted within 30 days after period end. Cause - The Authority's policies and procedures over federal award reporting were not adequate. Recommendation - The Authority should implement policies and procedures related to federal award reporting to comply with reporting requirements. Views of Responsible Officials - The Authority agrees with the finding. The Authority will implement additional oversight over the timely preparation and submittal of required grant reporting documents.