2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.
2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.
2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.
2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.
2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.
2024-001 – Internal Control over Compliance and Compliance with Reporting Information on the Major Federal Program: Federal Agency: Department of Interior Program Name: National Park Service Second Century Endowment and Appropriation Assistance Listing Number: 15.U01 Award Number: H.R. 4680/P.L. 114-289 Award Period: October 1, 2023 to September 30, 2024 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of the Federal Funding and Accountability Act (FFATA), which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, the Foundation is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. Condition – During our testing of reporting, we selected fourteen subrecipient awards. For all samples tested, the Foundation did not comply with the mandatory FFATA report filing requirements. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 14 14 14 Not applicable – no report was submitted Not applicable – no report was submitted Dollar Amount of Tested 2024 Subawards Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 4,984,134 $ 4,984,134 $ 4,984,134 Not applicable – no report was submitted Not applicable – no report was submitted Cause - The Foundation did not have adequate policies and procedures in place to ensure compliance with the FFATA filing requirements. Effect or Potential Effect - Failure to comply with the reporting requirements of the Uniform Guidance could result in noncompliance and awarding agency taking administrative action. Questioned Costs – None. Context - This is a condition identified based upon our review of the Foundation’s compliance with specified requirements. The sample was selected based on a non-statistical basis. The prevalence of these finding is detailed in the condition section above. Repeat Finding – This is a repeat finding from prior year. This was reported as finding 2023-003 in the 2023 report. Recommendation – BDO noted management’s actions to address prior year finding, however, the Foundation’s grant agreement do not have a Federal Award Identification Number (FAIN) which is a requirement to file FFATA, management is still unable to file the required FFATA reporting. BDO recommends that the Foundation continue to work with federal grantor/agencies to determine the required information and immediately file the required requirements. Views of Responsible Officials – The Foundation’s management has been given a legal opinion from counsel that the Appropriation and the Endowment are exempt from Uniform Guidance and the Single Audit. As such, will continue to work with Department of Interior to remedy this situation. The planned corrective actions are presented in the Foundation’s management’s corrective action plan attached as Appendix C.
2024-001 – Internal Control over Compliance and Compliance with Reporting Information on the Major Federal Program: Federal Agency: Department of Interior Program Name: National Park Service Second Century Endowment and Appropriation Assistance Listing Number: 15.U01 Award Number: H.R. 4680/P.L. 114-289 Award Period: October 1, 2023 to September 30, 2024 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of the Federal Funding and Accountability Act (FFATA), which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, the Foundation is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. Condition – During our testing of reporting, we selected fourteen subrecipient awards. For all samples tested, the Foundation did not comply with the mandatory FFATA report filing requirements. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 14 14 14 Not applicable – no report was submitted Not applicable – no report was submitted Dollar Amount of Tested 2024 Subawards Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 4,984,134 $ 4,984,134 $ 4,984,134 Not applicable – no report was submitted Not applicable – no report was submitted Cause - The Foundation did not have adequate policies and procedures in place to ensure compliance with the FFATA filing requirements. Effect or Potential Effect - Failure to comply with the reporting requirements of the Uniform Guidance could result in noncompliance and awarding agency taking administrative action. Questioned Costs – None. Context - This is a condition identified based upon our review of the Foundation’s compliance with specified requirements. The sample was selected based on a non-statistical basis. The prevalence of these finding is detailed in the condition section above. Repeat Finding – This is a repeat finding from prior year. This was reported as finding 2023-003 in the 2023 report. Recommendation – BDO noted management’s actions to address prior year finding, however, the Foundation’s grant agreement do not have a Federal Award Identification Number (FAIN) which is a requirement to file FFATA, management is still unable to file the required FFATA reporting. BDO recommends that the Foundation continue to work with federal grantor/agencies to determine the required information and immediately file the required requirements. Views of Responsible Officials – The Foundation’s management has been given a legal opinion from counsel that the Appropriation and the Endowment are exempt from Uniform Guidance and the Single Audit. As such, will continue to work with Department of Interior to remedy this situation. The planned corrective actions are presented in the Foundation’s management’s corrective action plan attached as Appendix C.
2024-002 Internal Controls over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Requirements (Significant Deficiency) Information on the Federal Program: U.S. Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA22GR00225 May 13, 2022 through May 10, 2024 720BHA22GR00127 April 15, 2022 through April 14, 2024 Criteria or Specific Requirement: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D ‐ Post Federal Award Requirements, Section 200.303 ‐ Internal Controls, requires the auditee to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with a framework such as the “Internal Control Integrated Framework”, issued by the COSO. In accordance with 2 CFR §200. 308, 200.309, and 200.403(h), a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. A period of performance may contain one or more budget periods. Condition: During our testing of the activities allowed or unallowed and allowable costs/cost principles compliance requirements, we identified one disbursement sample out of a total of twenty-five disbursement samples tested wherein management charged the federal program on June 2024 when the transaction happened on December 2022. In particular, the inventory distribution in the amount of $4,258.53 that took place in December 2022 should have been recorded as an expense in fiscal year 2023 rather than in fiscal year 2024. In addition, during our testing of period of performance compliance requirements, we also noted another inventory distribution in the amount of $235.89 that took place on August 2023 but it was only recorded on June 2024. The expenditures are allowable and within the period of performance, however, the controls over timely reconciliation and recording the inventory distributions did not occur in the appropriate reporting period. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS’s compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: Delays in performing the reconciliation and timely recording of inventory distributions in certain CRS country offices were caused by personnel’s unfamiliarity with the use of the new Supply Chain Management system, a system used in inventory management. Effect: Failure to timely reconcile and record transactions in the correct accounting period results in incorrect SEFA reporting to the U.S. government. Repeat Finding: No. Recommendation: We recommend that management ensure timely reconciliation of inventory distributions in order to record the transactions in the correct accounting period. In addition, management should conduct appropriate training to CRS country office personnel with the proper use of the Supply Chain Management system to ensure timely reconciliation and recording of inventory distributions. Views of Responsible Officials: CRS management agrees with the finding and recommendations and will enhance the inventory reconciliation processes.
2024-002 Internal Controls over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Requirements (Significant Deficiency) Information on the Federal Program: U.S. Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA22GR00225 May 13, 2022 through May 10, 2024 720BHA22GR00127 April 15, 2022 through April 14, 2024 Criteria or Specific Requirement: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D ‐ Post Federal Award Requirements, Section 200.303 ‐ Internal Controls, requires the auditee to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with a framework such as the “Internal Control Integrated Framework”, issued by the COSO. In accordance with 2 CFR §200. 308, 200.309, and 200.403(h), a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. A period of performance may contain one or more budget periods. Condition: During our testing of the activities allowed or unallowed and allowable costs/cost principles compliance requirements, we identified one disbursement sample out of a total of twenty-five disbursement samples tested wherein management charged the federal program on June 2024 when the transaction happened on December 2022. In particular, the inventory distribution in the amount of $4,258.53 that took place in December 2022 should have been recorded as an expense in fiscal year 2023 rather than in fiscal year 2024. In addition, during our testing of period of performance compliance requirements, we also noted another inventory distribution in the amount of $235.89 that took place on August 2023 but it was only recorded on June 2024. The expenditures are allowable and within the period of performance, however, the controls over timely reconciliation and recording the inventory distributions did not occur in the appropriate reporting period. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS’s compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: Delays in performing the reconciliation and timely recording of inventory distributions in certain CRS country offices were caused by personnel’s unfamiliarity with the use of the new Supply Chain Management system, a system used in inventory management. Effect: Failure to timely reconcile and record transactions in the correct accounting period results in incorrect SEFA reporting to the U.S. government. Repeat Finding: No. Recommendation: We recommend that management ensure timely reconciliation of inventory distributions in order to record the transactions in the correct accounting period. In addition, management should conduct appropriate training to CRS country office personnel with the proper use of the Supply Chain Management system to ensure timely reconciliation and recording of inventory distributions. Views of Responsible Officials: CRS management agrees with the finding and recommendations and will enhance the inventory reconciliation processes.
2024-003 Internal Controls over Compliance and Compliance with Period of Performance Requirement (Significant Deficiency) Information on the Federal Program: U.S. Department of Agriculture Assistance Listing Number: 10.612 Assistance Listing Name: USDA Local and Regional Food Aid Procurement Program Grant Award Number: Direct Award Number Award Period LRP-686-2019/015-00-A October 1, 2019 through September 30, 2024 Criteria or Specific Requirement: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D ‐ Post Federal Award Requirements, Section 200.303 ‐ Internal Controls, requires the auditee to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with a framework such as the “Internal Control Integrated Framework”, issued by the COSO. In accordance with 2 CFR §200. 308, 200.309, and 200.403(h), a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. A period of performance may contain one or more budget periods. Condition: During our testing of the period of performance compliance requirements, we identified two disbursement samples for a total of $1,574.09 out of a total of twenty-five disbursement samples tested wherein management was unable to provide evidence that the expenditures charged to the program were valid and incurred within the appropriate period of performance. Management also subsequently concluded that these transactions should have been captured as inventory and not charged as expenditure to the federal program. Questioned Costs: $1,574.09 from our samples. Context: This is a condition based on testing of CRS’s compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method. The total amount of the twenty-five samples selected for testing was $62,914. Cause: CRS country office personnel did not adhere to CRS’s documented policies and procedures for ensuring only valid and allowable expenses are charged to the federal program within the appropriate period of performance. Effect: Without adequate internal controls in place to ensure costs are properly reviewed for allowability and appropriate period of performance, CRS could be noncompliant with the allowability and period of performance requirements and could request funds for costs that are unallowed. Repeat Finding: No. Recommendation: We recommend that management follow its own policies, procedures and controls to ensure that the inventory expenses charged to the federal program are allowable within the period of performance. Views of Responsible Officials: CRS management agrees with the finding and recommendations and will enhance processes around inventory expense allowability.
2024-004 Internal Controls over Compliance and Compliance with Equipment and Real Property Management (Significant Deficiency) Information on the Federal Program: U.S. Department of Agriculture Assistance Listing Number: 10.606 Assistance Listing Name: Food for Progress Grant Award Number: Direct Award Number Award Period FCC-521-2016/012-00 September 29, 2016 through September 30, 2025 Criteria or Specific Requirement: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D ‐ Post Federal Award Requirements, Section 200.303 ‐ Internal Controls, requires the auditee to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with a framework such as the “Internal Control Integrated Framework”, issued by the COSO. Also, a physical inventory of property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Condition: During our testing of the equipment and real property management compliance requirements, we noted that there is no formally documented physical count of property acquired using federal funds in 2024 specific to Haiti. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS’s compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS country office personnel did not adhere to CRS’s documented policies and procedures for ensuring proper compliance with monitoring of property acquired using federal funds. Effect: Failure to conduct physical inventory of property could lead to misappropriation of assets and noncompliance with Federal regulations resulting in return of Federal awards received. Repeat Finding: No. Recommendation: We recommend that management implement policies, procedures and controls that will ensure the physical counts of property are conducted, that evidence of a count is formally documented and an authorized individual formally approves the result of the count, and the related reconciliation of property records, in order to adhere to Federal regulations related to equipment management and its related maintenance. Views of Responsible Officials: CRS management agrees with the finding and recommendations and will enhance processes surrounding property reconciliation.
Criteria: According to §200.303 Internal controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to the Uniform Guidance (2 CFR Part 200), specifically §200.400 - 200.475, costs charged to federal awards must be reasonable, allocable, and allowable under the terms of the award. Condition and Context: Management was unable to provide sufficient documentation for specific COVID-19 expenditures that were initially reported on the Schedule of Expenditures of Federal Awards. As a result, audit adjustments were necessary to revise the total COVID-19 expenditures to include only those amounts that could be adequately substantiated. Cause: The lack of sufficient documentation was primarily due to a lack of adequate internal controls and oversight regarding the classification and allocation of COVID-19 expenditures charged to federal awards. Effect: Management did not have sufficient documentation to support activities met the terms and conditions related to the COVID-19 Indian Self-Determination federal awards. Audit adjustments were necessary to revise the total COVID-19 expenditures to include only those amounts that could be adequately substantiated. Questioned Cost: None. Repeat Finding: No Recommendation: We recommend the Hospital establish and document clear policies and procedures for identifying, classifying, and allocating costs charged to federal awards, ensuring compliance with the Uniform Guidance. Additionally, we recommend the Hospital conduct regular reviews of expenditures charged to federal awards to ensure compliance with federal regulations and the terms of the awards. Views of Responsible Officials: The Finance team of Financial Controller and Senior Accountant are responsible for gathering sufficient documentation specific to COVID-19 expenditures. Proper and accurate classification and allocation of COVID-19 related activities and expenditures will be tracked and monitored before charging to funds. This will be completed by September 30, 2025.
U.S. Department of Agriculture Federal Assistance Listing #10.766 Community Facilities Loans and Grants Applicable Federal Award Number – Direct Loan and Guaranteed Loan Special Tests and Provisions Significant Deficiency in Internal Control Over Compliance and Noncompliance Not Considered Material Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Medical Center was required to establish reserve accounts with deposits equal to 10% of the annual debt service requirement on the direct loan and guaranteed loan for the entire year. The Medical Center did not establish these accounts until August 2024. Although the reserve was fully funded by year-end, the reserve was not funded the entire year, as required. Cause: This deficiency is due to a misunderstanding of establishing reserve accounts as Salina Regional Health Center is the centralized cash management agent for the Medical Center. Once this was identified, the Medical Center worked with the bank to establish a reserve. Effect: The Medical Center was not in compliance with the terms of the loan agreements related to the reserve funds until August 2024. Questioned Costs: None. Context: Sampling was not used. Repeat Finding from Prior Years: Yes. Recommendation: We recommend management implement a control process to ensure the reserve is fully funded throughout the entire year. Views of Responsible Officials: Management agrees with the finding.
2024-002 Procurement Space Operations Assistance Listing Number: 43.007 Federal Award ID Number: 80JSC018M0005 National Aeronautics and Space Administration 2024 Funding, Repeat Finding Criteria: 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. 2 CFR Section 200.320 and 48 CFR section 52.244-5 sets forth the requirements for acquisition contracts awarded to vendors including the requirement to obtain price or rate quotations from an adequate number of qualified sources and the circumstances in which noncompetitive procurement methods can be used. Also, CASIS’s procurement policy states that it is in both CASIS and NASA’s interest to compete when it makes sense regardless of the threshold and can be achieved by obtaining three quotes, i.e., comparative shopping. A minimum of 3 vendors are required to demonstrate competition. CASIS may solicit a proposal from only one source in circumstances where one or more of the following conditions apply (FAR Subpart 6.3): (i) The item or service is available only from a single source. supplies or services to be procured immediately. (iii) NASA specifically authorizes the use of noncompetitive proposals (directed source). (iv) After consultation with a number of sources, competition is determined inadequate. (v) The vendor is listed as a sole source provider under the Cooperative Agreement. Condition: Sole source determination was not documented for two vendors. Cause: For two legal expenses tested in the sample, no documentation of this being a sole source purchase prior to expending the funds. Effect: If CASIS cannot demonstrate that procurement of services were properly sole sourced, this may result in questioned costs and funds being returned to NASA. Questioned Costs: Known questioned costs of $41,762 and likely questioned costs of $90,024. Perspective: There were 2 out of 60 expenses selected for which the control failed. Recommendation: Non-competitive procurement should be documented and approved prior to incurring expenses. Management Response: CASIS acknowledges the error documenting these procurements. The two legal service vendors had been discussed internally and the selections rationalized based on the specialty of the professional services required for leasing and employment matters. Unfortunately, the documentation was not completed and stored as required by our internal policies. We consider these costs to be both necessary and reasonable, as we were negotiating a new office space lease and the rates were consistent with other legal service providers that CASIS has procured. CASIS plans on reinforcing the procurement documentation requirements with our personnel through additional training and reminding that engagement letters need to go through our document review software.
U.S. Department of Energy 2024-001 – Weatherization Assistance for Low-Income Persons (Weatherization) – Assistance Listing No. 81.042, Passed through the Commonwealth of Massachusetts, Pass-through identifying number CT OCD SCOCD410024330000301, Grant Period – Year Ended June 30, 2025. Condition: Action, Inc. (the Agency) did not follow its internal controls regarding the monthly reporting for the Weatherization grant and as a result, the Agency included private utility grant costs within one of the Agency’s Weatherization monthly reports to the grantor for which the Agency was reimbursed for. Criteria: 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. In addition, the Agency can only request federal reimbursement for federally incurred allowable costs. Cause: The Agency did not properly follow its internal controls. Effect: The Agency did not follow its internal controls for reporting a federal reimbursement request for one month and included non-federal charges within the reimbursement request. Context: One out of seven monthly reports sampled. Our sample was not a statistically valid sample. This was not a repeat finding from a prior period. Questioned Costs: None Recommendations: Management should ensure that the Agency’s internal controls in place are properly followed. Management Response: Management agrees with the finding. During the year, the Agency had staff turnover which was one factor of the reporting error. Management will enhance its internal controls to ensure that monthly reporting only reflects federally related activity.
U.S. Department of Energy 2024-001 – Weatherization Assistance for Low-Income Persons (Weatherization) – Assistance Listing No. 81.042, Passed through the Commonwealth of Massachusetts, Pass-through identifying number CT OCD SCOCD410024330000301, Grant Period – Year Ended June 30, 2025. Condition: Action, Inc. (the Agency) did not follow its internal controls regarding the monthly reporting for the Weatherization grant and as a result, the Agency included private utility grant costs within one of the Agency’s Weatherization monthly reports to the grantor for which the Agency was reimbursed for. Criteria: 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. In addition, the Agency can only request federal reimbursement for federally incurred allowable costs. Cause: The Agency did not properly follow its internal controls. Effect: The Agency did not follow its internal controls for reporting a federal reimbursement request for one month and included non-federal charges within the reimbursement request. Context: One out of seven monthly reports sampled. Our sample was not a statistically valid sample. This was not a repeat finding from a prior period. Questioned Costs: None Recommendations: Management should ensure that the Agency’s internal controls in place are properly followed. Management Response: Management agrees with the finding. During the year, the Agency had staff turnover which was one factor of the reporting error. Management will enhance its internal controls to ensure that monthly reporting only reflects federally related activity.
U.S. Department of Energy 2024-001 – Weatherization Assistance for Low-Income Persons (Weatherization) – Assistance Listing No. 81.042, Passed through the Commonwealth of Massachusetts, Pass-through identifying number CT OCD SCOCD410024330000301, Grant Period – Year Ended June 30, 2025. Condition: Action, Inc. (the Agency) did not follow its internal controls regarding the monthly reporting for the Weatherization grant and as a result, the Agency included private utility grant costs within one of the Agency’s Weatherization monthly reports to the grantor for which the Agency was reimbursed for. Criteria: 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. In addition, the Agency can only request federal reimbursement for federally incurred allowable costs. Cause: The Agency did not properly follow its internal controls. Effect: The Agency did not follow its internal controls for reporting a federal reimbursement request for one month and included non-federal charges within the reimbursement request. Context: One out of seven monthly reports sampled. Our sample was not a statistically valid sample. This was not a repeat finding from a prior period. Questioned Costs: None Recommendations: Management should ensure that the Agency’s internal controls in place are properly followed. Management Response: Management agrees with the finding. During the year, the Agency had staff turnover which was one factor of the reporting error. Management will enhance its internal controls to ensure that monthly reporting only reflects federally related activity.
Assistance Listing Number(s): 93.575 Name of Federal Program or Cluster: CCDF Cluster Name of Federal Agency: Department of Health and Human Services Name of Pass-through Entity: Minnesota Department of Human Services Award Period: 7/1/2020-6/30/2024 and 7/1/2024-6/30/2026 Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations (CFR) section 200.303 requires non-federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Condition: The Registry, Inc. did not obtain support from the employee for time and effort used as the basis for allocating personnel costs to federal awards. Cause: The Registry, Inc. did not properly design policies and procedures to ensure time and effort reporting is maintained by employees, adequately and contemporaneously documented, and reviewed by supervisors or managers. Effect or Potential Effect: Costs not supported by adequate documentation could be disallowed. Repeat Finding: No. Recommendation: The Registry, Inc. should obtain time and effort documentation that supports the distribution of the employee's salary or wages among specific activities. The Registry, Inc. should design and implement written policies and procedures for personnel to document time spent on grant activities for every pay period, or monthly at a minimum. Views of Responsible Officials: The Registry, Inc. will implement written policies and procedures for personnel to document time spent on grant activities.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-014 – Cash Management (Significant Deficiency and Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health). Criteria: 2 CFR 200.305 establishes methods of receiving payment from federal agencies. 2 CFR 200.303 established that recipients must establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to the City's approved fiscal policies and procedures, drawdown reports/reimbursement requests must be approved by the grants department and accounting manager or CFO. Condition: The City drew the remaining balance on the Minority Health award during the year. Documentation of review and approval for the draw was not available. Cause: The City is experiencing turnovers and staffing challenges which have led to some gaps in following procedures. Effect: The City did not document proper controls in place over cash management. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen procedures to ensure it complies with its policies and procedures to ensure appropriate level of management is reviewing cash drawdown requests. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Assistance Listing Number: 66.468 Program Title: Capitalization Grants for Drinking Water Revolving Fund Pass-through Entity: Alabama Department of Environmental Management Contract Number and Year: FS010055.02 2022 Finding Type: Significant Deficiency Known Questioned Costs: None Criteria - 2 CFR Section 200.303(a) requires nonfederal entities receiving federal awards to establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. 2 CFR 200.305 Federal Payment requires nonfederal entities to establish written procedures to implement the requirements of cash management of federal funding. Condition - The Organization received federal funds prior to paying contractors and had no written procedures in place for appropriately handling those funds. Cause - The Organization has not developed or implemented written procedures for appropriately handling advance federal funds. Effect - Possible noncompliance with cash management requirements of the program. Recommendation - The Organization should develop, implement and comply with written procedures to meet the requirements of 2 CFR Section 200.303(a) and 2 CFR 200.305 Federal Payment. View of Responsible Officials - The General Manager has implemented policies and procedures so the Utilities Board of the City of Oneonta will not request advance payments. Payments to contractors will issue within 10 business days of receipt of approval from Project Engineer. In the event contractors can not be paid within 30 days, advanced funds received will be deposited into a designated insured interest bearing account until contractors are paid.
2024-003 Timely Report Submission ALN 14.228 Community Development Block Grant/State’s Program and Non-entitlement Grants in Hawaii Department of Housing and Urban Development Passed through Florida Department of Economic Opportunity Fiscal Year 2024 Funding Criteria: Per 2 CFR Part 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 CDBG award agreement requires quarterly performance reporting within 10 days of the end of the fiscal quarter, monthly progress reports and due 10 days after month end, annual compliance certification is due 60 days after year end, and HUD-2516 is due every April 15th and October 15th. Condition: Six of the eight CDBG reports tested were not submitted by the required deadlines. Cause of the condition: The City does not have established procedures to prompt management or City Officials to submit reports by the required deadlines. Potential effect of condition: The granting agency could rescind funding for continued noncompliance. Questioned Costs: None noted. Recommendation: The City should create a process to alert/remind management and City officials to meet the reporting requirements and deadlines. Management Response: The City recognizes the need for timely grant reporting and has recently added a Grants Administrator position to the Finance Department who has created a grant report tracking process.
2024-003 Timely Report Submission ALN 14.228 Community Development Block Grant/State’s Program and Non-entitlement Grants in Hawaii Department of Housing and Urban Development Passed through Florida Department of Economic Opportunity Fiscal Year 2024 Funding Criteria: Per 2 CFR Part 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 CDBG award agreement requires quarterly performance reporting within 10 days of the end of the fiscal quarter, monthly progress reports and due 10 days after month end, annual compliance certification is due 60 days after year end, and HUD-2516 is due every April 15th and October 15th. Condition: Six of the eight CDBG reports tested were not submitted by the required deadlines. Cause of the condition: The City does not have established procedures to prompt management or City Officials to submit reports by the required deadlines. Potential effect of condition: The granting agency could rescind funding for continued noncompliance. Questioned Costs: None noted. Recommendation: The City should create a process to alert/remind management and City officials to meet the reporting requirements and deadlines. Management Response: The City recognizes the need for timely grant reporting and has recently added a Grants Administrator position to the Finance Department who has created a grant report tracking process.
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.
2024-002 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