FINDING 2024-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY2024 Pass-Through Entity: Indiana Finance Authority Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into subawards and covered transactions with COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF), recipients are required to verify that contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (e.g., grant agreement) that are expected to equal or exceed $25,000 and all subawards. The verification is to be done by checking the System for Award Management (SAM) Excluded Parties List System (EPLS), collecting a certification from the person or entity, or adding a clause or condition to the covered transaction with that person or entity. One covered transaction paid from the SLFRF award during the audit period was identified and tested. The covered transaction, totaling $262,504, did not include the appropriate provisions in the contract, nor did the Town require a certification or check the SAM EPLS to ensure the entity was not suspended or debarred prior to entering into the contract. The lack of internal controls and noncompliance was isolated to the instance noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or INDIANA STATE BOARD OF ACCOUNTS 20 TOWN OF FLORA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause Management of the Town did not develop a system of internal controls to ensure that policies and procedures related to suspension and debarment were in place and followed as they were unaware of the requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the Town could not ensure the vendors paid with federal funds were eligible to participate in federal programs. Any program funds the Town used to pay vendors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Furthermore, noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the Town. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the Town develop written policies and procedures to ensure its compliance with requirements related to suspension and debarment. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY2024 Pass-Through Entity: Indiana Finance Authority Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context Recipients are required to submit quarterly or annual Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon type of recipient and its population, as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. INDIANA STATE BOARD OF ACCOUNTS 21 TOWN OF FLORA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The Town was classified as a metropolitan town with a population below 250,000 residents that received an allocation of less than $10 million in COVID-19 - Coronavirus State and Local Fiscal Recovery Funds. The annual report was to cover one calendar year and must be submitted to the Treasury by April 30, 2024. The Town submitted the required P&E report during the audit period timely, and the report agreed to the Town's records. However, there were no internal controls in place to prevent, or detect and correct, errors in the P&E report prior to submission. The Clerk-Treasurer prepared and submitted the P&E report without an oversight or review process in place. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause The Town's management did not have properly designed internal controls in place to review reports prior to submission. Effect Without the proper implementation of an effectively designed system of internal controls over reporting, the Town could not ensure that the report submitted was materially accurate and correct. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the Town establish a system of internal controls to provide for segregation of duties in the preparation and review of federal reports prior to submission. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2024-002 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Prior Year Finding Number: N/A Year of Finding Origination: 2024 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of the Treasury Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: Direct, Not Provided Pass-Through Agency: Direct and City of Saint Paul Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 2 U.S. Code of Federal Regulations §§ 200.403(a) and 200.403(g) require costs to be necessary and reasonable, and be adequately documented. Condition: The County did not obtain itemized documentation for five out of 44 disbursements tested. Questioned Costs: $181,377; known questioned costs were determined based on individual expenditures with exceptions identified. Context: The County treated one vendor as a subrecipient and approved a budget for this vendor by type of expenditure. The County monitored the vendor's actual expenditures against approved budgeted expenditures. Total expenditures reported on the Schedule of Expenditures of Federal Awards is $50,901,938 for this program. The sample tested included approximately $2,570,500. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Additionally, four individually important items were selected for testing. Effect: The County has insufficient documentation to demonstrate expenditures were for allowable activities and met the requirements of allowable costs. Cause: The County felt its procedures over monitoring actual expenditures to budgeted expenditures were sufficient in lieu of reviewing itemized supporting documentation. Recommendation: We recommend the County obtain supporting documentation related to expenditures, including payroll reports and supporting receipts for purchases, sufficient to determine expenditures were for allowable activities. View of Responsible Official: Concur.
2024-003 Eligibility and Child Support Non-Cooperation Prior Year Finding Number: N/A Year of Finding Origination: 2024 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Health and Human Services Program: 93.558 Temporary Assistance for Needy Families Award Number and Year: 2401MNTANF; 2024 Pass-Through Agency: Minnesota Department of Human Services Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 42 United States Code § 602(a)(1)(B)(iii) requires each state to create a written document that shall set forth the objective criteria for the delivery of benefits and the determination of eligibility. The Minnesota Department of Human Services’ State Plan for Temporary Assistance for Needy Families (TANF) and Minn. Stat. § 256J.10 [see now Minn. Stat. § 142G.10, subd. 1] establish the general eligibility requirements for TANF benefits. Title 45 U.S. Code of Federal Regulations § 264.30 states: “What procedures exist to ensure cooperation with the child support enforcement requirements? (a)(1) The State agency must refer all appropriate individuals in the family of a child, for whom paternity has not been established or for whom a child support order needs to be established, modified, or enforced, to the child support enforcement agency (i.e., the IV-D agency). (2) Referred individuals must cooperate in establishing paternity and in establishing, modifying, or enforcing a support order with respect to the child. (b) If the IV-D agency determines that an individual is not cooperating, and the individual does not qualify for a good cause or other exception established by the State agency responsible for making good cause determinations in accordance with section 454(29) of the Act or for a good cause domestic violence waiver granted in accordance with § 260.52 of this chapter, then the IV-D agency must notify the IV-A agency promptly. (c) The IV-A agency must then take appropriate action by: (1) Deducting from the assistance that would otherwise be provided to the family of the individual an amount equal to not less than 25 percent of the amount of such assistance; or (2) Denying the family any assistance under the program.” Condition: The Minnesota Department of Human Services maintains the computer system, MAXIS, which is used by Ramsey County to support the eligibility determination process. In the case files reviewed for eligibility, not all documentation was available, updated, or input correctly to support participant eligibility. The following exceptions were noted in the sample of 40 MAXIS case files tested: • one case file where the relationship between the minor child and the parent or other caretaker relative was not documented, • one case file where the social security number of one member of the assistance unit was not documented, and • one case file where the income in MAXIS did not agree with the supporting documentation on file. In a sample of 11 cases with non-cooperation in establishing paternity tested, an exception was noted in one case file where sanctions were not imposed for four months when they should have been based on supporting documentation on file. Questioned Costs: Not applicable. The County administers the program, but the State of Minnesota pays benefits to participants in this program. Context: The State of Minnesota and Ramsey County split the eligibility determination process. Pursuant to Minnesota statutes, Ramsey County performs the “intake function” needed for this program, while the State maintains the MAXIS system, which supports the eligibility determination process. Participants receive benefit payments from the State. The total population of eligible participants was 4,025. Child support non-cooperation is determined by the County, and the Providing Resources to Improve Support in Minnesota (PRISM) system maintains the information and recipient status. When a Child Support Officer at the County updates PRISM to show non-cooperation, it interfaces with MAXIS. From this interface, MAXIS receives a Worker’s Daily Report message which notifies the entity of child support non-cooperation. The County is responsible for updating the recipient’s record in MAXIS, including entering child support sanctions, or closing a case on the seventh occurrence of noncompliance. The total population of cases of non-cooperation at the County was 370. Sample sizes were based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: The lack of updated information in MAXIS documenting verification of key eligibility-determining factors increases the risk that program participants will receive benefits when they are not eligible. In addition, benefit overpayments could be paid when child support non-cooperation is not properly processed for a benefit month. Cause: Program personnel entering case data into MAXIS did not ensure all required information was input correctly, supported, and obtained or retained. Recommendation: We recommend the County implement additional procedures to provide reasonable assurance that all necessary documentation to support eligibility determinations exists, information is properly input or updated in MAXIS, and child support non-cooperation case files benefits are being reduced as necessary in MAXIS. In addition, the County should consider providing further training to program personnel. View of Responsible Official: Concur.
2024-004 Eligibility Prior Year Finding Number: N/A Year of Finding Origination: 2024 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Material Weakness and Modified Opinion Federal Agency: U.S. Department of Health and Human Services Program: 93.778 Medical Assistance Program Award Number and Year: 2405MN5ADM; 2024 Pass-Through Agency: Minnesota Department of Human Services Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 42 U.S. Code of Federal Regulations §§ 435.911 and 435.945 require the state Medicaid agency to determine and verify eligibility of enrollees in Medicaid. The Minnesota Department of Human Services provides the Minnesota Health Care Programs Eligibility Policy Manual. The manual contains the Minnesota Department of Human Services eligibility policies for the Minnesota Health Care Programs, including the eligibility requirements of Medical Assistance. Specific eligibility requirements are included for participants’ citizenship verification, income limits, applications, and asset verification. Minnesota Statutes, Section 256B.05, requires county agencies to administer Medical Assistance. Condition: The Minnesota Department of Human Services maintains the computer system, MAXIS, which is used by Ramsey County to support the eligibility determination process. In the case files reviewed for eligibility, not all documentation was available, updated, or input correctly to support participant eligibility. The following exceptions were noted in the sample of 40 MAXIS case files tested: • two case files where the verification of citizenship was not documented, • one case file where the application was not documented, • two case files where the verification of income was not documented or documentation did not agree with MAXIS, and • nine case files where the verification of assets was not documented or documentation did not agree with MAXIS. Questioned Costs: Not applicable. The County administers the program, but the State of Minnesota pays benefits to participants in this program. Context: The State of Minnesota and Ramsey County split the eligibility determination process. Pursuant to Minnesota statutes, Ramsey County performs the “intake function” needed for this program, while the State maintains the MAXIS system, which supports the eligibility determination process. Participants receive benefit payments from the State. The total population of eligible participants was 32,937. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: The lack of updated information in MAXIS documenting verification of key eligibility-determining factors increases the risk that program participants will receive benefits when they are not eligible. Cause: Program personnel entering case data into MAXIS did not ensure all required information was input correctly, supported, and obtained or retained. Recommendation: We recommend the County implement additional procedures to provide reasonable assurance that all necessary documentation to support eligibility determinations exists and information is properly input or updated in MAXIS. In addition, the County should consider providing further training to program personnel. View of Responsible Official: Concur.
Finding 2024- 007 – Timecard Approval Controls – Payroll Charge to Federal Grant, Significant Deficiency Federal award agency: US Department of Transportation Federal Transit Administration Program name and ALN: Federal Transit Cluster ALN 20.507 Federal Transit Formula Grants, ALN 20.525 State of Good Repair Grants Federal award identification number: IL-2017-028-00, IL-2018-024-00, IL-2019-022-01, IL-2021-050-00, IL-2022-005-01, IL-2022-032-00, IL-2023-036-01, IL-2024-025-00 Federal award year: 2017, 2018, 2019, 2022, 2023, 2024 Criteria: The Uniform Guidance requires non‑Federal entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award (2 CFR §200.303). In addition, payroll costs charged to Federal awards must be adequately supported and properly authorized to ensure that only allowable and accurate costs are charged (2 CFR §200.430(i)). Condition: During testing of payroll transactions charged to the Federal program, RSM identified instances in which employee timecards were not supported by evidence of timely supervisory review and approval. Specifically, for certain timecards tested, approval either could not be substantiated, occurred after fiscal year end, or lacked documentation evidencing the date of approval. Cause: Management did not consistently maintain documentation evidencing timely supervisory review and approval of employee timecards charged to Federal grants. Additionally, monitoring controls over the timeliness of timecard approvals were not sufficient to ensure compliance with established payroll control procedures. Effect or potential effect: Without timely supervisory approval of timecards, there is an increased risk that unallowable, inaccurate, or improperly allocated payroll costs could be charged to Federal awards. Questioned costs: None noted. Context: 16 control exceptions out of 60 selections. The sample was not intended to be, and was not, a statistically valid sample. Recommendation: RSM recommends that management strengthen internal controls over payroll charged to Federal grants by ensuring that all employee timecards are reviewed and approved by supervisors in a timely manner and that documentation evidencing the approval date is retained. Management should also implement periodic monitoring to verify compliance with timecard approval requirements. Views of responsible officials: Management acknowledges the finding and agrees that remediation is necessary. Management will implement the recommendations that it has defined within the corrective action plan required by Title 2 CFR 200.511(c) executed on April 16, 2026.
FINDING 2024-001 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: N/A – Direct Grant Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Noncompliance Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . .” 2 CFR 200.320 states in part: “The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases — (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . . “ 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: The City did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. The City had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for small purchase and simplified acquisition procurement thresholds were followed. Cause: The City had not developed a system of internal controls that would have ensured compliance with Procurement and Suspension and Debarment compliance requirements for covered transactions. Effect: Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, procurement procedures for goods and services were not adhered to and vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. The failure to comply with the grant agreement and the compliance requirement could have resulted in the loss of federal funds to the City. Questioned costs: There are no questioned costs. Context: For one out of three samples selected for the small purchase procurement threshold, three quotes and rationale for selecting the vendor were not documented. Small purchase procurements require three competing quotes and rationale for selection of the vendor. The procurement was for park improvement design services. The City was unaware that professional services are required to follow the federal procurement process. Per grant requirements, all grant funded expenditures require appropriate procurement, regardless of whether it is a good or service. For two out of three samples selected for suspension and debarment testing, the City did not have support that vendors procured under CSLFRF funding were not suspended or debarred. Identification as a repeat finding, if applicable: Yes, finding 2023-003 in the prior year report. Recommendation: We recommend that the City establish and implement control procedures to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. This should include ensuring proper procurement methods are followed, suspension and debarment checks are performed and documented prior to entering into the transaction. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.
Rural eConnectivity Pilot Program U.S. Department of Agriculture Loan ID MO1704-A59, April 2, 2020 – April 1, 2043 Criteria or Specific Requirement – Internal Controls over Compliance (2 CFR 200.303(a). non‑federal entities must establish and maintain effective internal controls over Federal awards, including segregation of duties to reasonably ensure reports submitted to the federal awarding agency or a pass-through entity include all activity of the reporting period, are supported by underlying accounting or performance records, and are fairly presented in accordance with governing requirements. Condition – The Cooperative did not maintain appropriate segregation of duties for approval of quarterly reports. Specifically, reports were not separately reviewed for completeness and accuracy by an individual in management at the appropriate level, the same individual prepared and approved the quarterly reports. Cause – The Cooperative’s internal controls were not adequate to ensure reports submitted were reviewed by a separate individual. The Cooperative had not assigned separate personnel to perform the preparation and approval functions for required quarterly reports. Effect or Potential Effect – A lack of segregation of duties increases the risk that errors or omissions in quarterly reports may not be prevented or detected in a timely manner. As a result, reports submitted to USDA may be inaccurate or incomplete. Questioned Costs – None Context – We selected a sample of two out of four quarterly reports submitted during the year for detailed testing. For both reports documentation showed the same individual was responsible for both preparing and approving the submissions. The sampling methodology used is not, and is not intended to be, statistically valid. Identification of a Repeat Finding – Yes Recommendation – The Cooperative should implement internal control procedures that ensure adequate segregation of duties for the preparation and approval of quarterly reports. At a minimum, report preparation and approval responsibilities should be assigned to different individuals. Views of Responsible Officials and Planned Corrective Actions – The Cooperative concurs with the finding and management will implement procedures to ensure appropriate segregation of duties are in place for reporting requirements.
2024-003 Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: 2024; FAIN not available. Award Period: January 1, 2024 through December 31, 2024 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material weakness in internal control over compliance Criteria or Specific Requirement: The United States Code of Federal Regulations (CFR) Title 2, Part 200.319 indicates procurement transactions under the Federal award must be conducted in a manner that provides full and open competition. Additionally, 2 CFR Part 200.320 indicates that for any allowable method chosen, the recipient or subrecipient must maintain and use documented procurement procedures, consistent with the requirements of 2 CFR Part 200, Subpart D. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR Part 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Part 180.300). 2 CFR Part 200.303 indicates that non-Federal entities receiving Federal awards 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. Condition: The Borough did not maintain documentation to support the suspension and debarment procedures performed for covered transactions in order to demonstrate compliance with 2 CFR Part 180 and 2 CFR Part 200. Questioned Costs: None. Context: One (1) of two (2) selections subject to suspension and debarment compliance requirements did not include adequate documentation to demonstrate that the Borough properly verified the vendor was not suspended or debarred prior to entering into the services agreement. Cause: Procedures were not implemented to maintain documentation to support compliance with the standards of suspension and debarment contained in 2 CFR Part 180 and 2 CFR Part 200. Effect: Compliance with the requirements of the federal award could not be demonstrated. Repeat Finding: No Recommendation: We recommend management enhance procedures and controls to ensure documentation is maintained to support all suspension and debarment verifications related to expenditures from federal award programs. Such documentation should be consolidated and maintained in a secure, accessible location. Views of Responsible Officials: Management agrees with the finding.
(3) Findings and Questioned Costs Relating to Federal Awards Finding No. 2024 002 Loan Origination Involving Fraudulent Documentation Program Name: EDA Revolving Loan Fund Program Capital Allocation - New York Contractor Loans (a non-major program) Federal Department/Agency: U.S. Department of Commerce Economic Development Administration Assistance Listing Number: 11.307 Federal Award Year: January 1, 2024 December 31, 2024 Grant Number Award #01-79-15074 Compliance Requirements: Activities Allowed and Unallowed and Allowable Costs Criteria Federal regulations and the Organization’s own policies require effective internal controls to ensure that loans, including those funded by federal programs, are made only to eligible, legitimate recipients and are properly authorized and documented. Specifically, 2 CFR §200.303 (Internal Controls) mandates that recipients of federal funds establish effective controls to safeguard assets and ensure proper use of federal awards. 2 CFR Part 200 establishes cost principles for determining costs applicable to federal awards with nonprofit organizations. The Uniform Guidance (2 CFR 200.403) requires that costs charged to federal awards be necessary, reasonable, allocable, adequately documented, and in compliance with the terms and conditions of the federal award. The Organization’s Contractor Mobilization Loan Program guidelines also require verification of each subcontractor’s legitimacy and confirmation of their engagement by a general contractor before loan disbursement. Condition and context In 2025, management conducted an internal review that uncovered several instances of fraud within the Organization’s Contractor Mobilization Loan Program. One of the loans, valued at $410,000, was funded using a grant provided by a U.S. Department of Commerce Economic Development Administration (EDA). The Schedule of Expenditures of Federal Awards includes approximately $3.3 million in federal expenditures related to EDA grants. The internal review determined that the borrower was not a legitimate subcontractor and did not hold contractual relationships or involvement with the general contractor identified in the loan applications; consequently, the loan was determined to be fraudulent. Furthermore, during the approval process, the employee responsible for verifying subcontractor eligibility misrepresented to the Organization’s underwriters that appropriate due diligence, including confirmation of existence and project participation from general contractor had been completed. However, those verifications were not performed, resulting in the loan being issued based on inaccurate information. Cause The primary cause of this finding was a gap in internal controls and oversight that allowed required due diligence procedures to be bypassed. The designated loan officer responsible for verifying subcontractors’ legitimacy failed to perform the mandated verification steps and misrepresented to underwriters that all requisite due diligence had been completed including claims of general contractor confirmation. This misrepresentation was possible due to a lack of segregation of duties in the loan approval process which enabled the loan officer to circumvent controls without detection. The Organization relied on a single designated individual to verify subcontractor legitimacy and project approval without sufficient independent checks or supervisory review. Effect This gap in the control resulted in the disbursement of $410,000 from a U.S. Department of Commerce Economic Development Administration grant to a an illegitimate subcontractor who did not hold contractual relationships or involvement with the general contractor. This lack of proper segregation of duties represents a material weakness in internal control over financial reporting and material noncompliance with federal award requirements. Questioned Costs $410,000. Statistical Sample Not applicable Repeat Finding A similar finding was not reported in the prior year. Recommendation We recommend that the Organization’s management design and implement enhanced internal control procedures over the subcontractor verification process that include considerations regarding segregation of duties, independent verification of general contractors, enhanced communication protocols and employee training. Views of Responsible Officials Management acknowledges the questioned cost and the need for improved controls as highlighted in this audit finding. However, the borrower referenced in this finding was a registered business whose corporate credentials and credit history were verified through standard underwriting procedures at the time of origination. The issue pertains specifically to documentation intended to demonstrate subcontractor engagement with general contractors, which was subsequently found to be invalid following further examination. In response, management has implemented several corrective actions including the adoption of a Know Your Customer (KYC) Policy, a Fraud and Suspicious Activity Reporting Policy and a Mandatory Leave Policy. Collectively, these policies introduce enhanced verification procedures, multiple and independent contractor confirmation requirements, comprehensive IRS tax transcript reviews, new fraud and suspicious activity reporting protocols, site visits, annual borrower review requirements and mandatory leave for employees in sensitive positions. Additionally, an independent Internal Audit function will be established in the third quarter of 2026. The matter referenced in this finding is currently the subject of a criminal investigation, and all characterizations of employee conduct remain alleged until the investigation concludes. Subsequent to year-end and prior to the issuance of this report, TruFund received instructions from the EDA to replenish the EDA Revolving Loan Fund with the $410,000 question cost and complied with those instructions.
2024-001 REPORTING - SIGNIFICANT DEFICIENCY Federal Program Community Development Block Grant-Entitlement/Special Purpose Grants Cluster ALN 14.218; passed through the County of Berks COVID-19 - Emergency Rental Assistance ALN 21.023; passed through the County of Berks Criteria Per 2 CFR §200.303, non-federal entities must establish and maintain effective internal control over federal awards to provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of the award. The OMB Compliance Supplement for reporting requires entities to have controls to ensure accurate and timely submission of required reports. Condition/Cause The auditee did not have any documented or implemented internal controls over the review of federal program reporting requirements. Reports were prepared and submitted without documentation of supervisory review or verification of accuracy and completeness. Management did not design or implement procedures to review reports prior to submission, relying solely on preparer knowledge without formal oversight. Effect Without internal controls, there is an increased risk that reports submitted to the federal agency or pass-through entity may contain inaccurate or incomplete information, potentially resulting in noncompliance with reporting requirements. Questioned Costs None. Repeat Finding Yes; 2023-01. Recommendation We recommend that all grant reports are reviewed by a person independent of the preparer who has knowledge of the grant requirements. This review should include comparing the amounts reported to detailed support for accuracy. We also recommend the Authority review their recordkeeping procedures for documentation related to grant reporting. There should be a process in place to ensure all required documentation is maintained and filed in an orderly system that allows the Authority to locate and provide documentation when required. Management Response In general, management agrees with the finding. It should be noted that internal controls for supervisory review of reporting requirements were in place but were not written controls or processes. Reporting for the CDBG Program is accomplished through the preparation of the annual Comprehensive Annual Performance and Evaluation Report (CAPER). Written policies and procedures for the CAPER have been developed. Reporting for the Emergency Rental Assistance Program is accomplished through an online reporting system of the U.S. Treasury and by email to the Pennsylvania Human Services Department. This finding has since been resolved in 2025, with a new policy developed and implemented on December 12, 2025.
Finding 2024-002 Information on the federal program: Federal Agency: Federal Transportation Administration Pass-Through Entity: N/A Federal Program: Federal Transit Cluster Assistance Listing Number: 20.507 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs – Cost Principles Audit Findings: Material Weakness Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Within the sample of 42, we noted that 9 timecards for bus operators did not have documented review. Documented review was implemented in September 2024. All instances of the error were prior to September 2024. We also noted 1 timecard showed 2 hours more than reflected on the pay register, resulting in a net underpayment. Effect: Payroll expenditures could be inaccurately charged as an allowable activity or allowable costs to the federal grant. Cause: Management noted that time is tracked in a spreadsheet and is reviewed but formal documentation of review was not maintained. Questioned Costs: None. Identification as a Repeat Finding, if Applicable: This is a repeat finding. See finding 2023-001 in the prior report. Recommendation: We recommend the Corporation maintain documented approval of all timecards. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Significant deficiency in internal control over compliance and compliance as it relates to allowable costs and activities. Federal Agency: All awards within the Research and Development Cluster Program Title: All awards within the Research and Development Cluster Assistance Listing Number: All awards within the Research and Development Cluster Award Number: All awards within the Research and Development Cluster Award Period: All awards within the Research and Development Cluster Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Section 200.303 requires that each recipient of federal awards “Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition/Context for Evaluation During our audit, we tested nonpayroll costs charged to the federal awards for adherence to necessary compliance requirements and internal control over compliance requirements. Out of 25 sample selections, we noted the following related to seven sample items: - Five of seven sample items selected involved overcharges to the grants. All five showed management approval for the incorrect amounts. - One of seven sample items selected had no supporting documentation. - One of seven sample items had no management approval. Questioned Costs $1,790 Effect or Potential Effect AAHI may have charged unallowable or incorrect costs to the federal awards. Repeat Finding No. Recommendation We recommend AAHI implement the necessary internal controls to (1) ensure documentation is retained to support costs spent on federal awards and (2) ensure all costs are properly approved and for the correct amounts. Views of Responsible Officials of Auditee Management concurs with the finding and has provided the accompanying corrective action plan.
2024-007: Bureau of Indian Affairs – 105(l) Leases ALN 15.048, Lack of Approvals (Material Weakness) Condition There were several instances of lack of approvals for disbursements. Criteria Federal grant recipients are required to maintain effective internal controls over federal awards, as outlined in 2 CFR §200.303. Cause Turnover and inadequate staffing. Effect Some disbursements had no approvals. Perspective Information Nine of 27 tested. Recommendation All disbursements should have one approval and ensure the expenditure is eligible under the grant. View of Responsible Officials and Planned Corrective Action The Tribe has taken steps to strengthen internal controls over disbursement approvals and ensure that all expenditures are properly reviewed and documented including: Establishment of a standardized disbursement approval process requiring documented approval prior to payment for non-routine/recurring expenditures. Implementation of procedures to ensure all disbursements are reviewed for allowability under applicable grant requirements before payment is issued. Maintenance of supporting documentation, including approval evidence, within the accounting records. Ongoing review of disbursement procedures to ensure compliance with internal control requirements under 2 CFR §200.303. These measures are designed to ensure that all disbursements are properly authorized, documented, and compliant with applicable grant requirements. Corrective actions began implementation during throughout 2025. These procedures are currently in place and will continue to be refined as part of ongoing internal control improvements.
FINDING 2024‐001 – Allowable Cost Principles and Activities Allowed or Unallowed Material Weakness in Internal Control over Compliance Assistance Listing Number: 21.029 Federal Program Name: COVID-19 - Coronavirus Capital Projects Fund Award Year: 2024 Criteria: Uniform Guidance requires non-Federal entities to establish and maintain effective internal controls over Federal awards, including ensuring transactions are properly recorded, reported, and allowable. Specifically: • 2 CFR §200.302(b)(1) and (b)(2) require financial management systems to provide accurate, current, and complete disclosure of financial results and to identify expenditures by Federal award. • 2 CFR §200.302(b)(6) requires written procedures for determining the allowability of costs. • 2 CFR §200.303 requires entities to establish and maintain effective internal controls over compliance, including appropriate segregation of duties. Condition and context: The Cooperative does not have formalized written policies and procedures governing the coding, review, and reporting of expenditures charged to Federal awards, including payroll costs. Additionally, adequate segregation of duties is not in place over the review and approval of expenditure coding and financial reporting. As a result, payroll expenditures were not consistently or timely coded to the appropriate grant. Payroll expenditures totaling $16,990 were identified subsequent to year-end and recorded and reported late. These costs were not included in the appropriate reporting period, resulting in delayed recognition of allowable expenditures. Questioned costs: None. Effect: The absence of formal policies, procedures, and proper segregation of duties increases the risk that expenditures are not accurately, completely, or timely recorded and reported by Federal award. This may result in: • Financial reports that do not reflect complete and accurate program expenditures for the reporting period; • Increased risk of noncompliance with Federal reporting requirements; • Potential misstatement or omission of allowable costs; and • Delays in reimbursement or increased risk of questioned costs. Additionally, the late identification and backdating of payroll expenditures contributed to the triggering of Single Audit requirements, which are now being performed after the required timeframe. Cause: The deficiencies are due to a lack of formalized written policies and procedures over expenditure coding, allowability determinations, and reporting, as well as inadequate segregation of duties in the preparation, review, and approval of grant-related expenditures and reports. Repeat finding: No Recommendation: We recommend the Cooperative develop and implement written policies and procedures to ensure timely, consistent, and correct coding of all grant-related expenditures (payroll and non-payroll). Within these policies and procedures, we recommend establishing review and approval controls, including periodic review of expenditure coding by supervisory or accounting personnel. Implementing these policies and procedures will ensure expenditures are recorded within the appropriate reporting period. Views of responsible officials and planned corrective actions: Wabash currently maintains informal procedures for coding and reviewing invoices and payroll records, management recognizes the need for a formalized, written policy governing expenditures charged to federal awards. To address identified material weaknesses, Wabash is committed to implementing a comprehensive written policy by June 30, 2026. This policy will formalize the coding, review, and reporting processes for all federal expenditures. Contact Person(s): Cheryl Gaither, Controller Justin Gephart, Chief Operating Officer
Significant deficiency in internal control over compliance and compliance as it relates to allowable costs and activities. Federal Agency: All awards within the Research and Development Cluster Program Title: All awards within the Research and Development Cluster Assistance Listing Number: All awards within the Research and Development Cluster Award Number: All awards within the Research and Development Cluster Award Period: All awards within the Research and Development Cluster Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Section 200.303 requires that each recipient of federal awards “Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition/Context for Evaluation During our audit, we tested nonpayroll costs charged to the federal awards for adherence to necessary compliance requirements and internal control over compliance requirements. Out of 25 sample selections, we noted the following related to seven sample items: - Five of seven sample items selected involved overcharges to the grants. All five showed management approval for the incorrect amounts. - One of seven sample items selected had no supporting documentation. - One of seven sample items had no management approval. Questioned Costs $1,790 Effect or Potential Effect AAHI may have charged unallowable or incorrect costs to the federal awards. Repeat Finding No. Recommendation We recommend AAHI implement the necessary internal controls to (1) ensure documentation is retained to support costs spent on federal awards and (2) ensure all costs are properly approved and for the correct amounts. Views of Responsible Officials of Auditee Management concurs with the finding and has provided the accompanying corrective action plan.
Finding Number:2024-006 Instance of Non-Compliance:Allowability of Costs Assistance Listing # 66.466 Questioned Cost $0 Repeat Finding: No Condition: During testing of disbursements, including both federal grant expenditures and nonfederal funded transactions, it was noted that a majority of the sampled items lacked documented evidence of review and approval. While approvals may have occurred, there was no retained written or system-based documentation to substantiate that such reviews were performed in accordance with the organization’s established approval requirements. Criteria: In accordance with 2 CFR Part 200, specifically § 200.303 (Internal Controls), nonfederal entities are required to establish and maintain effective internal controls over federal awards, including proper authorization and documentation of transactions. Additionally, the Organization’s accounting policies require that all disbursements and employee reimbursements be reviewed and approved by appropriate personnel, with supporting documentation maintained within designated systems such as QuickBooks Online (QBO) and Gusto. Cause: The deficiency appears to result from inconsistent adherence to established policies and procedures, as well as insufficient monitoring and enforcement controls to ensure that approvals are properly documented and retained within the accounting system. Effect: The lack of documented approvals increases the risk of unauthorized, inappropriate, or unsupported expenditures. This control weakness may result in noncompliance with federal regulations and internal policies and could lead to questioned costs or additional audit findings. Recommendation: Management should strengthen internal controls by reinforcing compliance with existing approval and documentation requirements. Specifically, all disbursements and reimbursements should include verifiable evidence of review and approval (e.g., documented electronic approvals within QBO or Gusto, or appropriately signed supporting documentation) prior to payment processing. Additionally, management should implement periodic monitoring procedures to ensure compliance and provide training to relevant personnel on documentation and approval standards. Views of Responsible Officials: Management acknowledges the finding and agrees that documentation of disbursement approvals needs to be strengthened. While approvals were generally occurring, they were not consistently documented or retained in accordance with established policies. To address this, the organization has implemented a requirement for documented email approvals from appropriate managers prior to processing payments. In addition, the organization is evaluating and implementing an electronic system to capture and retain approvals for accounts payable and credit card transactions. Management will also reinforce compliance through periodic monitoring and staff training to ensure adherence to approval and documentation requirements. Responsible Official: Abel Olivo, Executive Director, in coordination with the organization’s outsourced accounting firm Anticipated Completion Date: May 31, 2026
Criteria: Per 2 CFR § 200.303(a), the non-Federal entity must establish, document, and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the awards. Additionally, per 2 CFR §200.403 and §200.302, costs charged to federal awards must be allowable, allocable, and properly documented, and financial reporting must be accurate, complete, and supported by the accounting system. Condition: Although the Parish has implemented internal controls related to the allowability of costs and the preparation of required reports for the Coronavirus State and Local Fiscal Recovery funds, they were not operating effectively during fiscal year 2024. Tests of controls indicated that transactions were not tracked appropriately to ensure they were charged to the correct funding source. In addition, quarterly project and expenditure reports submitted to the U.S. Treasury included inaccurate or unsupported information due to a lack of tracking and reconciliation procedures. Cause: As discussed in item 2024-001, the Parish encountered several challenges during the transition of administration and key personnel. Parish administration and management were immediately tasked with enhancing operations related to procedural concerns from the prior administration and performing the accounting function without sufficient documentation on several balances and transactions. The documented controls were not in practice because of this. Effect: While no instances of noncompliance were noted, the lack of documented controls in practice increases the risk that future required reports could be incomplete, inaccurate, or untimely, as well as, federal costs being unallowed per the cost principles which could potentially result in program noncompliance. Recommendation: We recommend that the Parish enhance and document internal controls over financial reporting, as described in our recommendations described under item 2024-001, to prevent noncompliance of the Uniform Guidance as required. Views of responsible officials: See management’s responses to findings on Page 116.
Criteria: In accordance with 2 CFR § 200.331, a non-federal entity that passes federal awards to subrecipients is responsible for 1) evaluating each subrecipient’s risk of noncompliance, 2) monitoring the activities of subrecipients to ensure that the subaward is used for authorized purposes, in compliance with laws and the terms and conditions of the subaward, and 3) verifying that subrecipients have audits in accordance with the Uniform Guidance, if applicable. Adequate internal controls are required to ensure compliance with these requirements under 2 CFR § 200.303. Condition: During our audit, we noted that the Parish did not have sufficient internal controls in place to ensure effective subrecipient monitoring. Specifically, there was no documented risk assessment of subrecipients prior to issuing subawards, the Parish did not perform periodic reviews or site visits to monitor subrecipient performance or compliance, and the subrecipient audit reports were not consistently obtained or reviewed. Cause: As discussed in item 2024-001, the Parish encountered several challenges during the transition of administration and key personnel. Parish administration and management were immediately tasked with enhancing operations related to procedural concerns from the prior administration and performing the accounting function without sufficient documentation on several balances and transactions. The documented controls were not in practice because of this. Effect: Failure to properly monitor subrecipients increases the risk that federal funds may be misused or not spent in accordance with program requirements to achieve program objectives. It also exposes the Parish to potential liability for questioned costs incurred by subrecipients to be repaid to the federal agency. Recommendation: We recommend that the entity establish and implement formal policies and procedures for subrecipient monitoring in accordance with 2 CFR § 200.331. This should include conducting and documenting pre-award risk assessments, developing a subrecipient monitoring plan (e.g., site visits, desk reviews), reviewing subrecipient performance and audit reports on a regular basis. Views of responsible officials: See management’s responses to findings on Page 116
Finding 2024-004 Lack of documented approval of Other Than Personal Services (OTPS) expenditures charged to federal awards (Assistance Listings 19.510, 93.566, 93.583 and 93.576) Criteria: Under 2 CFR 200.303, the nonfederal entity must establish, document, and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award; those internal controls should align with the Green Book or COSO framework and include adequate authorization and review of disbursements. To be allowable under a federal award, costs must be necessary and reasonable, allocable, accorded consistent treatment, determined in accordance with GAAP, not used to meet cost-sharing of other federal programs, adequately documented, and incurred during the approved budget period per 2 CFR 200.403. Inadequate or missing documentation may result in costs being considered improper payments or disallowed costs. Condition and Context: During testing of OTPS expenditures charged to the programs, the Organization did not consistently document required management approval prior to payment. For 13 of 23 OTPS transactions tested, totaling $49,393, the supporting documentation did not contain evidence of review and approval by an individual with appropriate authority in accordance with the Organization’s written policies and procedures. In addition, for these items, there was no alternative documentation demonstrating that the costs had been reviewed for allowability, allocability, and reasonableness before being charged to the federal award. Cause: The Organization’s policies require documented approval for OTPS expenditures; however, management did not effectively enforce these procedures, and staff responsible for processing OTPS transactions were not consistently following the policy and procedures on the documentation and approval requirements. Effect: Because documented approval was not consistently obtained prior to payment, there is an increased risk that unallowable, unreasonable, or non-program-related OTPS costs could be charged to the federal award. The transactions identified without documented approval may be subject to disallowance by the federal awarding agency or pass-through entity. Identification as a repeat finding: No. Questioned costs: None. Recommendation: We recommend that management: Reinforce and, if necessary, update written policies and procedures to require documented review and approval of all OTPS expenditures charged to federal awards prior to payment, including documentation of the program, funding source, and allowability assessment. Provide training to staff responsible for initiating, reviewing, and approving OTPS transactions to ensure understanding of Uniform Guidance requirements for allowability, allocability, and documentation. Implement periodic monitoring (for example, supervisory review of a sample of OTPS transactions) to verify that approvals are documented and that OTPS costs charged to federal awards are properly supported and in compliance with 2 CFR 200.303 and 2 CFR 200.403. Views of Responsible Officials: The Organization proactively enacted rigorous internal controls and systemic enhancements for FY25 to ensure optimal oversight and adherence to federal guidelines. Management has addressed this recommendation by deploying a strict, comprehensive expense request process to ensure robust internal controls over all Other Than Personal Services (OTPS) expenditures. To ensure full compliance with 2 CFR 200.303 and 200.403, Finance has deployed the following enhancements to our accounts payable workflows: Strict Electronic Approval Workflow: Finance has established a stringent review and approval protocol that requires direct involvement from Program Directors and Department Heads. All OTPS expenditures are now routed through a formalized electronic workflow, which mandates documented review and secure electronic signatures from authorized leadership prior to any payment processing. System-Integrated Documentation: The new process strictly requires that all supporting documentation-including invoices, receipts, and evidence of allowability-be provided upfront. These documents are now uploaded and attached directly to the specific transaction within the accounting program, creating a permanent, easily accessible, and audit-ready trail for every federal charge. Targeted Training and Oversight: To support this modernized workflow, Finance is providing targeted training to all staff responsible for initiating and approving transactions, ensuring a clear understanding of Uniform Guidance requirements. Furthermore, Finance leadership conducts periodic supervisory reviews directly within the accounting system to verify that all electronic approvals are captured and source documents are properly attached.
Information on Federal Programs: 93.083 – Centers for Disease Control and Prevention: Prevention of Disease, Disability, and Death through Immunization & Control of Respiratory & Related Diseases. Criteria or Specific Requirements: 2 CFR §200.303 requires the non-Federal entity to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the award is managed 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 (Green Book), issued by the Comptroller General of the United States, or the COSO Internal Control Integrated Framework. 2 CFR §200.318-200.320 require the non-Federal entity to have and use documented procurement procedures for the acquisition of property or services under a Federal award that are consistent with the standards for general procurement, competition, and methods of procurement. Condition: ATS’s organization-wide procurement policy does not include documented procurement procedures that address the Uniform Guidance requirements for procurement under Federal awards (for example, methods of procurement, competition requirements, and applicable thresholds) as required by 2 CFR §200.318-200.320. For the federally funded program, ATS implemented a separate written selection policy for contractors/health systems; however, this policy does not fully address all Uniform Guidance procurement elements. Cause: Management had not fully updated its written procurement policies and procedures to incorporate the specific requirements of 2 CFR §200.318-200.320 for procurements under Federal awards. As a result, internal control procedures over procurement under the Federal program were not fully documented in a manner consistent with the Uniform Guidance. Effect: Failure to have and use fully documented procurement policies and procedures compliant with the Uniform Guidance could result in noncompliance with Federal procurement requirements and increase the risk of unallowable or improperly procured costs under Federal awards. In the current year, our testing did not identify specific instances in which procurement transactions under the Federal program were noncompliant; however, the lack of fully compliant written procedures represents a significant deficiency in internal control over compliance. Perspective: ATS did not have documented procurement policies and procedures that were fully compliant with 2 CFR §200.320 for procurement under Federal awards. However, for the Federal program, ATS established a documented selection criteria policy for contractors/health systems. Under this policy, a selection subcommittee reviews, evaluates, and selects health systems based on defined criteria, and each selected application is submitted to the prime awardee for review and approval before ATS issues contracts. In a random sample of 8 procurement contracts tested, all 8 followed the documented selection process and were supported by appropriate documentation. Questioned Costs: None. Identification as a Repeat Finding: Continued Finding 2023-005. Recommendation: ATS should update and formalize its procurement policies and procedures to incorporate the requirements of 2 CFR §200.318-200.320 for all procurements under Federal awards, including: methods of procurement and thresholds, competition requirements, documentation of procurement history, and oversight responsibilities. Once updated, ATS should ensure the procurement under the Federal program is carried out in accordance with these policies and that staff are trained on the revised requirements.
FINDING 2024-003 Subject: Water and Waste Disposal System for Rural Communities - Internal Controls Federal Agency: Department of Agriculture Federal Program: Water and Waste Disposal System for Rural Communities Assistance Listings Number: 10.760 Federal Award Number and Year (or Other Identifying Number): 1780-12 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the Town to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles. There was no documented oversight, review, or approval process in place over federal expenditures related to the grant. Although the Town Council approved grant project-related contracts, individual expenditures did not have a documented review process in place (or consistent Town Council approval) to ensure disbursements made were allowable and in accordance with contract provisions and the grant agreement. Additionally, related grant expenditures from the Town's Sewer Construction fund were not consistently or appropriately recorded in the Town's general ledger. The lack of internal controls was a systemic issue throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 18 TOWN OF NEW MARKET SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause The Town relied on its Rural Development Grant Administrator to handle approvals of related expenditures, reimbursements, and other grant compliance tasks. The Clerk-Treasurer is new to the position and is still working to implement internal controls over the Town's federal grant programs. Effect Without the proper implementation of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. It also placed the Town at risk of noncompliance with the grant agreement, as grant related disbursements without adequate review could be unallowable. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the Town design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight of grant related disbursements are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-004 Subject: Water and Waste Disposal System for Rural Communities - Equipment Federal Agency: Department of Agriculture Federal Program: Water and Waste Disposal System for Rural Communities Assistance Listings Number: 10.760 Federal Award Number and Year (or Other Identifying Number): 1780-12 Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 19 TOWN OF NEW MARKET SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The Town had not properly designed and implemented a system of internal controls to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. A property record or capital asset listing is required to be maintained for all equipment purchased with federal grant awards to ensure adequate safeguards are in place to prevent loss or damage of items. The Town disbursed federal funds for its Sewer Construction project and added $1,600,438 to its capital asset records in 2024 noted as "Infrastructure." None of the required information, including description of the property, a serial number or another identification number, the source of funding for the property (including the FAIN), the title holder, the acquisition date, the cost of the property, the percentage of the federal agency contribution towards the original purchase, the location, etc., was included in the Town's property/asset records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.313(d) states: "Management requirements. Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. INDIANA STATE BOARD OF ACCOUNTS 20 TOWN OF NEW MARKET SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return." Cause The Town was unaware of the requirements regarding identifying information for assets purchased with federal funds. The Clerk-Treasurer is new to the position and is still working to implement internal controls over the Town's federal grant programs. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, assets purchased with federal dollars were not properly identified in the Town's asset listing. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the Town. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the Town establish a proper system of internal controls and develop policies and procedures to ensure asset records include all the necessary information for assets purchased with federal funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: Water and Waste Disposal System for Rural Communities - Suspension and Debarment Federal Agency: Department of Agriculture Federal Program: Water and Waste Disposal System for Rural Communities Assistance Listings Number: 10.760 Federal Award Number and Year (or Other Identifying Number): 1780-12 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not in place at the Town to ensure compliance with requirements related to the grant agreement and the suspension and debarment portion of the Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 21 TOWN OF NEW MARKET SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Prior to entering into subawards and covered transactions with federal funds, recipients are required to verify that contractors and vendors are not suspended, debarred, or otherwise excluded from receiving those federal funds. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under procurement and nonprocurement transactions (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking SAM exclusions online, collecting a certification from that vendor/contractor, or adding a clause or condition to the covered transaction with that vendor/contractor. The Town had two contracted vendors related to this project with combined federal expenditures of $1,530,838 during the audit period including its engineering and main construction firms. The Town could not provide documentation that procedures were performed to verify that each of these vendors paid from the grant were not excluded or disqualified from participation in federal programs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause Town officials were unaware of the grant's requirements regarding suspension and debarment. The Town did not have a documented federal procurement policy to ensure that the suspension and debarment status of contractors and vendors receiving federal funds was conducted prior to entering into the covered transactions or contracts. The Clerk-Treasurer is new to the position and is still working to implement internal controls over the Town's federal grant programs. INDIANA STATE BOARD OF ACCOUNTS 22 TOWN OF NEW MARKET SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the Town cannot ensure the vendors paid with federal funds are eligible to participate in federal programs. Any program funds the Town used to pay vendors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions or the federal award could result in the loss of future federal funding to the Town. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Town adopt a federal procurement policy and implement a system of internal controls to ensure that all contractors and vendors that are paid $25,000 or more, all or in-part with federal funds, are not suspended or debarred from participating in federal programs before entering into any covered transactions. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-006 Subject: Water and Waste Disposal Systems for Rural Communities - Reporting Federal Agency: Department of Agriculture Federal Program: Water and Waste Disposal Systems for Rural Communities Assistance Listings Number: 10.760 Federal Award Number and Year (or Other Identifying Number): 1780-12 Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The Town had not designed or implemented adequate internal controls and procedures to ensure that reports were prepared, accurate, and submitted in accordance with the applicable compliance requirements for the federal grant. The United States Department of Agriculture (USDA) requires the following reports be submitted annually: • Statement of Budget, Income, and Equity (Form RD 442-2) • Balance Sheet (Form RD 442-3) The Form RD 442-2 covers financial operations relating to the Town's sewer construction and improvement project, and the Form RD 442-3 presents the financial status of the project. In both instances, a borrower may submit the financial data on other forms, provided the forms are in a similar format and signed and dated by the organization's official to certify the correctness of the information. Alternatively, an annual audit may be submitted in lieu of the forms. INDIANA STATE BOARD OF ACCOUNTS 23 TOWN OF NEW MARKET SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The Town was required to file each report, as noted above, during the audit period; however, the reports were not filed nor was an annual audit filed by the September 30, 2025 Single Audit deadline, as the Town did not report any federal expenditures to the USDA or the Indiana State Board of Accounts. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 1780.47(e) states in part: ". . . within 60 days following the end of each fiscal year, furnish the RUS with annual financial statements, consisting of a verification of the organization's balance sheet and statement of income and expense by an appropriate official of the organization. Forms RD 442-2, 'Statement of Budget, Income and Equity,' and 442-3 may be used." Cause The Town was unable to provide documentation to show that the Form RD 442-2 and the Form RD 442-3 reports were filed. The Clerk-Treasurer is new to the position and is still working to implement internal controls over the Town's federal grant programs. Effect Without the proper implementation of an effectively designed system of internal controls, the Town could not ensure that the required reports were filed with the awarding agency. As such, the awarding agency did not have accurate and current information to discern the financial status of the Town's project. Furthermore, noncompliance with the provisions of federal statutes, regulations, and the terms and conditions or the federal award could result in the loss of future federal funding to the Town. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 24 TOWN OF NEW MARKET SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the Town's management design and implement a system of internal controls that would provide segregation of duties for the preparation and review of federal reports to ensure appropriate reviews, approvals, and oversight are taking place. Additionally, management should develop policies and procedures to ensure that all required reports are filed timely and accurately and ensure that federal awards are properly reported to both the federal and state regulatory agencies to ensure the federal Single Audit deadline is met. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Criteria: HUD’s Continuum of Care program (ALN 14.267) requires that participant eligibility determinations, including income calculations and rent reasonableness assessments, be accurate, properly supported, and in compliance with program requirements. These determinations should be subject to appropriate internal control procedures, including review controls, to ensure accuracy and reduce the risk of error or conflict of interest. In accordance with 2 CFR § 200.303, organizations must establish and maintain effective internal controls over compliance, including segregation of duties and ongoing monitoring activities. Additionally, 24CFR § 578.103 requires recipients to maintain sufficient documentation to support eligibility determinations and related compliance requirements. Conditions: In a nonstatistical sample of 18 tenant files tested, there was no evidence of documented supervisory review of eligibility determinations, income calculations, or supporting documentation. These results indicate that controls designed to ensure completeness and accuracy of eligibility determinations are not operating effectively. Cause and Effect: This condition appears to be due to the absence of a formalized policy or consistent practice requiring documented supervisory review of eligibility determinations. We identified a significant deficiency in internal control over compliance related to this process. Although eligibility determinations were generally appropriate based on testing, the lack of documented review indicates that a key control is not operating effectively. This increases the risk that errors or noncompliance could occur and not be detected in a timely manner. No questioned costs were identified as a result of this condition. Recommendations: We recommend management strengthen controls over eligibility determinations by requiring documented supervisory review of all initial eligibility decisions and periodic file reviews. This review should be evidenced by a formal sign-off (electronic or manual) and include verification of key eligibility criteria. Management may also consider implementing a standardized review checklist to ensure consistency and completeness of the review process.
Criteria: HUD’s Continuum of Care program (ALN 14.267) requires that participant annual income be determined using gross income in accordance with 24 CFR § 5.609 and 24 CFR § 5.611, and that such determinations be supported by adequate and verifiable source documentation. Recipients are required to maintain complete and accurate participant files, including signed income certifications, zero-income affidavits where applicable, and sufficient third-party or source documentation (e.g., pay stubs) to support income calculations. In accordance with 2 CFR § 200.303, organizations must establish and maintain effective internal controls over compliance to ensure that income determinations and rent calculations are accurate, complete, and properly documented. Conditions: Our testing of 18 tenant files identified deficiencies in income documentation and rent calculation support. Specifically, 2 tenant files lacked documented zero-income verification, 2 files contained insufficient supporting pay documentation, 1 file was missing a signed income certification, and in 2 instances rent calculations were based on net wages rather than gross wages. These results indicate that controls over income verification and rent calculation documentation are not consistently operating effectively. Cause and Effect: This condition appears to be due to inconsistent application of documentation requirements and the absence of a formalized review process to ensure completeness and accuracy of income determinations and rent calculations. We identified a significant deficiency in internal control over compliance related to income verification and rent calculation documentation. While rent calculations appeared reasonable based on available information and no questioned costs were identified, the control deficiencies increase the risk that errors or noncompliance could occur and not be detected in a timely manner. Recommendations: We recommend management enhance controls over income verification and rent calculation documentation by implementing standardized documentation requirements and file checklists to ensure all required support (e.g., pay stubs, zero-income affidavits, and calculation worksheets) is obtained and retained prior to approval of assistance. Additionally, a secondary review should be performed and documented to verify the completeness and accuracy of income determinations and rent calculations.
Criteria: HUD’s Continuum of Care program (ALN 14.267) requires that rental assistance payments comply with rent reasonableness requirements in accordance with 24 CFR § 578.49. Rent reasonableness must be determined and documented prior to execution of the lease and before assistance is provided, and must be based on accurate lease terms, unit characteristics, and comparable market data. Additionally, participant income used in determining rent contributions must be calculated in accordance with 24 CFR § 5.609 and 24 CFR § 5.611. In accordance with 2 CFR § 200.303, organizations are required to establish and maintain effective internal controls over compliance to ensure that rent determinations are accurate, properly supported, and performed in a timely manner. Conditions: Our testing of 18 tenant files identified deficiencies in the timeliness and accuracy of rent reasonableness determinations. Specifically, in 4 instances, rent reasonableness calculations were performed after lease execution, and in 5 instances, the calculations were based on incorrect lease amounts. These results indicate that controls over the timeliness and accuracy of rent reasonableness determinations are not consistently operating effectively. Cause and Effect: This condition appears to be due to inadequate internal controls and monitoring procedures to ensure that rent reasonableness determinations are completed prior to lease execution and that lease terms are verified for accuracy before performing the analysis. We identified a significant deficiency in internal control over compliance related to rent reasonableness determinations. The lack of timely and accurate determinations increases the risk that the program could approve rents that exceed market rates, resulting in potential noncompliance with program requirements and inefficient use of program funds. No questioned costs were identified as a result of this condition. Recommendations: We recommend management implement formal procedures requiring that rent reasonableness determinations are completed and documented prior to lease execution and approval of assistance. Management should establish standardized checklists or workflows to ensure rent reasonableness is performed as a required step before assistance is authorized. Additionally, staff should be trained on these procedures and the importance of timely compliance. A secondary review process should be implemented to verify lease terms, unit data, and calculation accuracy. Periodic supervisory reviews should also be conducted to ensure compliance with documentation and timing requirements.
Criteria: HUD’s Continuum of Care program (ALN 14.267) requires recipients to maintain complete and accurate documentation to support participant eligibility and rental assistance in accordance with 24 CFR §578.103. Tenant-based rental assistance must be supported by a valid lease between the participant and landlord in accordance with applicable housing requirements (including 24 CFR § 982.305 and 24 CFR §982.309, as applicable through program guidance). Required participant protections and disclosures, including those under the Violence Against Women Act (VAWA), must be provided and documented in accordance with 24 CFR § 5.2005 and 24 CFR § 5.2009. In addition, housing quality standards and environmental requirements, including inspections and lead-based paint disclosures, must be completed and documented prior to assistance in accordance with 24 CFR § 982.401 and 24 CFR § 35.92. Furthermore, in accordance with 2 CFR § 200.303, organizations must establish and maintain effective internal controls to ensure required documentation is obtained, reviewed, and retained prior to the disbursement of federal funds. Where utilities are paid as a supportive service under 24 CFR § 578.51, appropriate documentation, including participant consent, must be maintained. Conditions: Our testing of 18 tenant files identified multiple instances of missing or incomplete required documentation. Specifically, 1 file lacked an executed lease agreement, 3 files contained leases with terms less than one year, 2 files were missing required RAP forms with VAWA addenda, 1 file lacked inspection documentation, 1 file was missing a Form W-9, and 1 file did not include a required lead-based paint disclosure. Additionally, among 2 Permanent Supportive Housing tenant files tested, 1 file lacked a required Consent to Pay Utilities form. These results indicate that controls over required documentation are not consistently operating effectively. Cause and Effect: This condition appears to be due to inadequate internal controls and monitoring procedures to ensure that all required documentation is obtained, completed, and retained prior to the approval and disbursement of rental assistance. Specifically, staff did not consistently utilize a standardized checklist or review process to verify file completeness. We identified a significant deficiency in internal control over compliance related to required documentation. The absence of required documentation increases the risk of noncompliance with program requirements, potential disallowance of costs, and repayment of federal funds. No questioned costs were identified as a result of this condition. Recommendations: We recommend management strengthen controls over required documentation by implementing a standardized pre-approval checklist to ensure all required documentation is obtained and verified prior to disbursement of assistance. This should include, at a minimum, a fully executed lease (including verification of lease term), RAP agreement and VAWA documentation, inspection and housing quality documentation, Form W-9, and required lead-based paint disclosures. For supportive services such as utility payments, required participant consent documentation should be obtained and retained prior to payment. Additionally, management should implement a documented secondary review process and perform periodic quality control reviews to ensure ongoing compliance. Staff should be trained on documentation requirements and file completion standards.
Criteria: HUD’s Continuum of Care program (ALN 14.267) requires recipients to provide and document matching contributions in accordance with 24 CFR § 578.73. Recipients must maintain adequate records to support the source and allowability of match contributions in accordance with 24 CFR § 578.103. In addition, in accordance with 2 CFR § 200.303, organizations are required to establish and maintain effective internal controls over compliance, including appropriate segregation of duties and review procedures, to ensure that match calculations and supporting documentation are accurate, complete, and properly supported. Conditions: Our testing of 2 Permanent Supportive Housing tenant files related to matching requirements identified that, in both instances, match calculations and supporting documentation were not reviewed and approved by an individual independent of the preparer. These results indicate that controls over the review and approval of match documentation are not operating effectively. Cause and Effect: This condition appears to be due to inadequate segregation of duties and the absence of a formalized independent review process over match calculations and supporting documentation. We identified a significant deficiency in internal control over compliance related to the matching requirement. The lack of independent review increases the risk that errors or noncompliance in match reporting could occur and not be detected in a timely manner. Although no questioned costs or instances of noncompliance were identified as a result of our testing, this control is considered important to ensuring ongoing compliance with program requirements. Recommendations: We recommend management strengthen controls over match reporting by enhancing segregation of duties and implementing an independent review process for match calculations and supporting documentation. Where full segregation of duties is not feasible, compensating controls—such as documented supervisory review by an individual not involved in preparation—should be implemented. Management should also establish formal procedures and standardized checklists to ensure match contributions are properly supported, reviewed, and approved prior to reporting. Periodic monitoring procedures should be performed to ensure continued compliance.
United States Department of the Treasury Reference Number: 2024-010 Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Federal Award Number: 51-6000255 Type of Finding: Noncompliance and Significant Deficiency in Internal Controls over Compliance Compliance Requirement: Reporting Condition: The following conditions were found during testing of the Town’s Annual Report for the period April 1, 2023 through March 31, 2024. 1. The Town’s procedures over the reporting did not include documentation of the preparation and review of the report. 2. Testing of the key line items- Obligations and Expenditures - Quantifiable Objective Criteria revealed the following: a. The Town reported the budgeted amount as cumulative obligations. b. The Town reported the same amount for current period obligations, current period expenditures and cumulative expenditures. The reported amount appeared to be the calculated amount of cumulative obligations. The support for the report did not appear to calculate the current period obligations or current period expenditures. A similar finding was reported in prior years’ audits. Criteria: United States Department of the Treasury State and Local Fiscal Recovery Funds Compliance and Reporting Guidance version 5.0 was issued September 20, 2022 and provides detailed reporting requirements 31 CFR §35.3 defines obligation and 2 CFR §200.1 defines expenditures. 2 CFR § 200.303 requires the implementation of effective internal controls: “Internal control requires the non-federal entity 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 conditions of the federal award.” Cause: The Town experienced turnover at key positions in the Finance Department during the year. Effect: The Town was not in compliance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) at 2 C.F.R. § 200.32 and the Guidance on Recipient Compliance and Reporting Responsibilities, issued by the U.S. Department of the Treasury. Recommendation: We recommend that the Finance Department enhance its processes and oversight surrounding grant financial reporting to ensure all required reports are completed accurately and timely. Views of Responsible Town Officials and Planned Corrective Actions: See corrective action plan. Responsible Positions: Town Manager and Director of Finance
Lack of Internal Controls over Substantially All Compliance Requirements Federal Agency: U.S. Department of Agriculture / U.S. Department of Education Federal Program: Child and Adult Care Food Program / Alaska Native Educational Programs ALN: 10.558 / 84.356A Award Numbers: 53301 / S356A210037 Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: Management is responsible for designing, implementing and maintaining internal controls relevant to ensuring that transactions charged to programs follow proper internal control processes (2 CFR Part 200 Subpart E §200.400 (d)). This includes ensuring there is proper supporting documentation for transactions as well as methods to document approval of the cost/activity to determine whether it is allowable under the funding requirements. Additionally, requirements relevant to maintaining effective internal control over Federal awards found in 2 CFR Part 200 Subpart E §200.303-Internal Controls are required to be implemented by grant recipients to provide reasonable assurance they are managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. Condition and context: We were unable to obtain sufficient audit evidence to support compliance with applicable compliance requirements for all major federal programs of the Organization including Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Eligibility, Period of Performance, Procurement and Suspension and Debarment, Reporting and Special Tests and Provisions. The Organization was unable to provide supporting documentation for auditor’s to verify compliance with the compliance requirements listed above. Cause: Insufficient monitoring by management and the board over the financial and other activities of the Club as well as employee turnover in several positions contributed to an ineffective control environment throughout the Organization. Effect: Because adequate supporting documentation was not available for expenditures charged to the program, we could not determine whether the costs charged to the programs were allowable and in compliance with the applicable requirements. Accordingly, we consider the entire amount of expenditures for these programs during the audit period to be likely questioned costs. Questioned Costs: Likely questioned costs: Alaska Native Educational Program (ALN 84.356A) $757,173 and Child and Adult Care Food Program (ALN 10.558) $274,693 are equal to total estimated program expenditures during the period, representing the auditor’s best estimate of total questioned costs (likely questioned costs) for these major programs due to lack of adequate supporting documentation. Repeat finding: No, however due to the number of issues identified we believe this to be a systemic issue. Recommendation: We recommend that management implement a stronger internal controls environment that includes adequate staffing to maintain a segregation of duties for an effective control environment as well as improving monitoring processes to ensure the Organization is in compliance with requirements applicable to Federal statutes, regulations, and the terms and conditions of the award Management’s Response: Management concurs with the finding. See Corrective Action Plan.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.329, recipients must submit performance reports as required by the Federal awarding agency and ensure such reports are accurate, complete, and submitted timely. Additionally, 2 CFR 200.303 requires the entity to establish and maintain effective internal controls over Federal awards, including controls that provide reasonable assurance that reporting requirements are met and that documentation is retained to support compliance. Condition: During testing of reporting, we noted the following: - Management stated that required reviews and approvals of performance reports were conducted in person, but the organization does not maintain documentation or an audit trail to evidence these reviews. While documentation was available for quarterly performance reports, 2 of 2 annual performance reports and 6 of 21 monthly performance reports tested lacked evidence of review and approval. - Additionally, 6 of 10 performance reports selected for testing were not submitted/uploaded timely in accordance with grantor requirements. Questioned costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed. Cause: The Organization has not established formalized policies and procedures governing the preparation, review, and timely submission of performance reports. As a result, responsibility for monitoring reporting deadlines and performing supervisory review was informal and not consistently documented. Effect: Failure to submit required performance reports timely increases the risk of noncompliance with federal award requirements and may result in adverse actions by the federal awarding agency, including delayed reimbursements or additional monitoring. Additionally, the lack of a documented review process increases the risk that performance reports may be incomplete, inaccurate, or not aligned with program requirements. Repeat finding: No Recommendation: We recommend the Organization develop and implement formal policies and procedures to ensure required performance reports are prepared, reviewed, and submitted in a timely manner. Such procedures should include clearly defined roles and responsibilities, tracking of reporting deadlines, and documented evidence of supervisory review and approval prior to submission. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, an entity is required to establish and maintain effective internal controls over Federal awards, including controls that provide reasonable assurance that reporting requirements are met and that documentation is retained to support compliance. Condition: During payroll testing, we noted for 2 of 60 payroll disbursements tested, the employee’s timecard was self‑approved by the individual whose time was being charged. There is no mitigating control in place to prevent or detect self‑approval of timecards or allocation of payroll costs. Questioned costs: None Context: At the time the timesheet was filed, there was no control system in place to prevent or detect such self-approval of timecards or allocation of payroll costs. The two instances noted were for the same employee and isolated to that specific employee. Cause: The Organization has not established formalized policies or supervisory procedures to prevent employees from self‑approving their own timecards. Effect: Self‑approval of timecards increases the risk of inaccurate or unsupported payroll charges, misallocation of labor costs, potential fraud or manipulation of reported hours, and reduced reliability of payroll and cost‑allocation data. Repeat finding: No Recommendation: We recommend the Organization develop and implement formal policies and procedures or workflow restrictions that prevent employees from self‑approving their own timecards. Views of responsible officials: There is no disagreement with the audit finding.
FINDING 2024-003 Subject: Highway Planning and Construction - Equipment and Real Property Management Federal Agency: Department of Transportation Federal Program: Highway Planning and Construction Assistance Listings Number: 20.205 Federal Award Number and Year (or Other Identifying Number): DES #9981680 Pass-Through Entity: Indiana Department of Transportation Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Modified Opinion Condition and Context A property record or capital asset listing is required to be maintained for all equipment, property improvements, and property purchased with the Highway Planning and Construction grant awards to ensure adequate safeguards are in place to prevent loss or damage of items. In addition, a complete physical inventory of the property must be taken every two years and reconciled with the detailed listing. The capital asset listing is to include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. The County purchased $734,389 of right-of-way for the Veterans Memorial Trail project. The project had a 20 percent local match; thus, the Highway Planning and Construction grant portion was $587,511. The right-of-way purchase should have been recorded as capital assets purchased with 80 percent federal funding. However, the County did not include the right-of-way purchased in the capital asset listing. The lack of internal controls and noncompliance were isolated to DES #9981680. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.313(d) states in part: "Management requirements. Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of dunking for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." Cause Effective internal controls were not in place to ensure that all capital assets purchased with federal funds, including rights-of-ways, were added to the County's capital asset listing. Effect Noncompliance with the grant agreement and the compliance requirement could result in the repayment of federal funds. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the County's management establish a proper system of internal controls that would ensure compliance with the Equipment and Real Property Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Federal Agency: U.S. Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Numbers and Years (or Other Identifying Numbers): Contract #65873, SLT-3157 Pass-Through Entity: Indiana Department of Natural Resources Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2023-004. Condition and Context Procurement The County did adopt an applicable federal purchasing policy. The Lake County Indiana Purchasing Manual for Supplies, Services, and Public Works states on page 19 that "Federal funds less than $25,000 will obtain 3 quotes by telephone or fax and obtain board approval. . . ." The Lake County Indiana Purchasing Manual for Supplies, Services, and Public Works also states on page 19 that "Federal funds more than $25,000 but less than $50,000 will invite 3 quotes at an open public meeting." The federal procurement requirement, per the Code of Federal Regulations section 200.320, states that for small purchases, price or rate quotations must be obtained from an adequate number of qualified sources. In 2024, the County had two vendors. One was paid $27,963, and one was paid $12,970 for a total of $40,933 from the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) under Contract #65873 from the Indiana Department of Natural Resources. However, the County did not obtain price or rate quotes for the applicable vendors under the small purchase threshold as required per its purchasing policy or the federal requirements. Suspension and Debarment Prior to entering into subawards and covered transactions with the SLFRF award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000 and all subawards. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person or entity, or adding a clause or condition to the covered transaction with that person or entity. The County did not have policies or procedures in place related to the suspension and debarment requirements for the SLFRF funds. Three covered transactions totaling $7,530,563 paid from the SLFRF funds were identified. Documentation to show that suspension and debarment was verified prior to entering into contracts with these three vendors could not be provided by the County. The amounts for which suspension and debarment were not verified for Contract #65873 from the Indiana Department of Natural Resources and the SLT-3157 directly from the U.S. Department of the Treasury were $27,963 and $7,502,600, respectively. The lack of internal controls and noncompliance were isolated to the transactions identified above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320 states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and §§200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases — (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause The County's purchasing policy does not provide procedures on how the County will ensure the appropriate number of quotes will be obtained for small purchases or how the County will ensure compliance with the suspension and debarment requirements. Effect Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the repayment or loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation Management of the County should develop procedures to ensure the appropriate procurement methods are used for items or services procured that are within the small purchase threshold and to ensure vendors are not suspended or debarred when expending federal funds. Appropriate documentation should be maintained to ensure compliance with procurement and suspension and debarment. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: U.S. Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): SLT-3157 Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2023-005. Condition and Context Recipients are required to submit quarterly or annual Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon type of recipient and its population as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. The County was classified as a county with a population that exceeds 250,000 residents. As such, the County was required to submit quarterly P&E reports in 2024. The amounts submitted for three of the four quarterly P&E reports were not supported by the County's records and contained the following errors: The 2024 Quarter 1 P&E report period and cumulative expenditures were each overstated by $333,424. The 2024 Quarter 2 P&E report period and cumulative expenditures were understated by $842,954 and $509,530, respectively. The 2024 Quarter 3 P&E report period and cumulative expenditures were understated by $239,925 and $749,455, respectively. Additionally, the current period obligations and cumulative obligations amounts reported in all quarterly reports could not be verified as supporting documentation was not provided for audit. The lack of internal controls and noncompliance was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds, page 13 states in part: ". . . 13. Reporting. All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. . . ." 31 CFR 35.4(c) states in part: "Reporting and requests for other information. During the period of performance, recipients shall provide to the Secretary or her delegate, as applicable, periodic reports providing detailed accounting of the uses of funds, . . ." Cause All quarterly P&E reports were prepared and submitted by a consultant without an oversight or review process in place to prevent, or detect and correct, errors prior to submission. Effect Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the repayment or loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the County's management establish a proper system of internal controls that would ensure compliance with the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-002 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Numbers and Years (or Other Identifying Numbers): TRSW 2200305, CY 2024 Pass-Through Entity: Indiana Finance Authority Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods or services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. Verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. The County had not properly implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. Covered transactions in the amount of $1,454,478 were made during the audit period to three vendors. A total of $60,732 was paid from the CY 2024 award to one vendor, and a total of $1,393,746 was paid from the TRSW 2200305 award to two vendors. Of the three vendors paid by the County, one vendor contract included a suspension and debarment clause with total payments of $917,636 from the TRSW 2200305 award. For the other two vendors, the County did not check the EPLS nor was a certification collected from the vendors, and a clause did not exist in the agreements with the vendors. One of the vendors was paid a total of $60,732 from the CY 2024 award, and the other vendor was paid $476,110 from the TRSW 2200305 award. Although the County had a policy to include a clause in vendor contracts related to covered transactions, a clause was not included in those two contracts and no other documentation to verify the County's compliance with the suspension and debarment federal requirement was provided for audit. The lack of internal controls and noncompliance were systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." 2 CFR 200.214 states: "Recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards." Cause The system of internal controls established by management of the County was not implemented as designed, and employees lacked sufficient training to carry out suspension and debarment procedures required to certify vendor status. Effect Without the proper implementation of an effectively designed system of internal controls, the system is incapable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the County was not able to provide documentation that the suspension and debarment requirements were followed for two vendors to whom payment was equal to or in excess of $25,000 was paid. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the County's management establish a system of internal controls to ensure compliance and comply with the grant agreements and the Procurement and Suspension and Debarment compliance requirement. Additionally, the County should ensure that all necessary personnel understand the requirements and County policies. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
U.S. Department of Treasury, COVID- 19 Coronavirus State and Local Fiscal Recovery Funds - 21.027 Criteria or Specific Requirement - Suspension and Debarment and Material Weakness In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. In accordance with 2 CFR Section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition - Suspension and debarment checks were not completed for a vendor prior to entering into a contract. Cause - The City's controls to ensure suspension and debarment checks on vendors receiving federal funds did not operate effectively. Effect - Federal funds could be paid to entities that are suspended or debarred. Questioned Costs - None noted, as the vendor was reviewed and determined to not be suspended or debarred. Context - The City entered into two contracts during the year ended December 31, 2024 that was considered a "covered transaction" and spent approximately $982,000 under this contract. Both contracts selected for testing suspension and debarment and uncovered the City did not check the vendor's suspension and debarment status prior to purchase for the $540,000 contract. The City completed the suspension and debarment check subsequent to purchase and verified the vendor was not suspended or disbarred. Identification as a Repeat Finding, if applicable - None noted. Recommendation - Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors prior to making purchases with federal funds. View of Responsible Official and Planned Corrective Actions - Management agrees with the stated finding and has implemented a corrective action plan.
Environmental Protection Agency Direct Program: Congressionally Mandated Projects - 66.202 Award Year: 2023 Criteria or Specific Requirement - Reporting Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) should establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Per the Environmental Protection Agency Congressionally Mandated Project's Programmatic Conditions, non-Federal entities that receive the federal award are required to submit semi-annual performance reports. Condition: During our test work over the Congressionally Mandated Projects grant, we noted the Board of Public Utilities did not timely file one of the required performance reports nor was there a review of the report prior to submission. Cause: The Board of Public Utilities' controls to ensure reports are filed timely and are reviewed prior to filing were not operating effectively. Effect or Potential Effect: Required reports are not being submitted timely. Questioned Costs - None Context: One out of the two semi-annual reports selected for testing was submitted on May 13, 2024, after the Environmental Protection Agency's due date of April 30, 2024. It was also noted through discussions with the Board of Public Utilties, no review of the report was completed prior to submission. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Recommendation: We recommend that the Board of Public Utilities implement a process that includes tracking the timely submission of reports and documenting review of the report prior to submission. Views of Responsible Official and Planned Corrective Action: Management agrees with finding. See corrective action plan.
Environmental Protection Agency Direct Program: Congressionally Mandated Projects - 66.202 Award Year: 2023 Criteria or Specific Requirement - Davis-Bacon Act Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) should establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Per the Environmental Protection Agency Congressionally Mandated Project's Programmatic Conditions, non-Federal entities that receive the federal award are required to maintain adequate records to demonstrate compliance with compensation requirements. Condition: During our test work over the Congressionally Mandated Projects grant, we noted the Board of Public Utilities did not obtain Statements of Compliance/Certified Payrolls from the applicable vendors in timely manner. Cause: The Board of Public Utilities' controls to ensure that the Statements of Compliance/Certified Payrolls are submitted timely were not operating effectively. Effect or Potential Effect: The Board of Public Utilities was unable to demonstrate compliance with Davis-Bacon wage rate requirements. Questioned Costs - None noted. Context: For all weeks selected for testing, the subcontractor did not submit the required Statements of Compliance within a timely manner. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Recommendation: We recommend that the Board of Public Utilities implement a process that includes tracking the timely submission of Statements of Compliance and documenting review of the Statements once received. Views of Responsible Official and Planned Corrective Action: Management agrees with finding. See corrective action plan.
FINDING 2024-002 Subject: Airport Improvement Program - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Transportation Federal Programs: Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and COVID-19 Airports Programs Assistance Listings Number: 20.106 Award Numbers or Years (or Other Identifying Numbers): 3-18-0025-018-2022, 3-18-0025-019-2023, 3-18-0025-020-2024, 3-18-0025-021-2024 Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Finding: Material Weakness Condition and Context Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The certified payrolls were completed and submitted weekly by the contractor as required; however, there were no internal controls in place at the Town that would be effective in preventing, or detecting and correcting, noncompliance. There was no evidence to ensure all applicable payrolls were received by the Town and that, once received, certified payrolls were reviewed by the Town to ensure that the wage rate compliance requirement was met. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause The Town did not design or implement a system of internal controls over the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Effect Without the proper implementation of an effectively designed system of internal controls, errors could occur and remain undetected. As such, the Town cannot ensure that the certified payrolls have been properly submitted and reviewed. INDIANA STATE BOARD OF ACCOUNTS 15 TOWN OF KENTLAND SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the Town design and implement a proper system of internal controls, including policies and procedures, to ensure that the Town is provided complete and accurate certified payrolls for the wage rate requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. INDIANA STATE BOARD OF ACCOUNTS 16
2024-007 Eligibility – MAXIS Prior Year Finding Number: N/A Year of Finding Origination: 2024 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Material Weakness and Modified Opinion Federal Agency: U.S. Department of Health and Human Services Program: 93.778 Grants to States for Medicaid Award Number and Year: 2405MN5ADM; 2024 Pass-Through Agency: Minnesota Department of Human Services Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 42 U.S. Code of Federal Regulations §§ 435.911 and 435.945 require the state Medicaid agency to determine and verify eligibility of enrollees in Medicaid. The Minnesota Department of Human Services provides the Minnesota Health Care Programs Eligibility Policy Manual. The manual contains the Minnesota Department of Human Services eligibility policies for the Minnesota Health Care Programs, including the eligibility requirements of Medical Assistance. Specific eligibility requirements are included for participants’ citizenship verification and asset verification. Minnesota Statutes, section 256B.05, requires county agencies to administer Medical Assistance. Condition: The Minnesota Department of Human Services maintains the computer system, MAXIS, which is used by Wilkin County to support the eligibility determination process. In the participant files reviewed for eligibility, not all documentation to support participant eligibility was available, updated, or input correctly. The following exceptions were noted in the sample of 40 participant files tested: • three participants’ citizenship information did not have the birth certificate in the file; and • one participant’s asset information did not match the documentation in the file, and three participant files did not have supporting asset documentation in the file. Questioned Costs: Not applicable. The County administers the program, but the State of Minnesota pays benefits to participants in this program. Context: The State of Minnesota and the County split the eligibility determination process. Pursuant to Minnesota statutes, Wilkin County performs the “intake function” needed for this program, while the State maintains the MAXIS systems, which supports the eligibility determination process. Participants receive benefit payments from the State. The population consisted of 336 active MAXIS participant cases enrolled in Grants to States for Medicaid in 2024; the sample size was 40 participant files. The sample size was based on the guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: The improper input or updating of information into MAXIS and the lack of verification or follow-up of eligibility-determining factors increase the risk that program participants will receive benefits when they are not eligible. Cause: Program personnel entering case file information into MAXIS did not ensure all required information was input or updated correctly, supported, and retained. Recommendation: We recommend Wilkin County implement additional procedures to provide reasonable assurance that all documentation needed to support eligibility determinations exists, the program personnel properly input or update the documentation in MAXIS, and the program personnel follow up on issues in a timely manner. In addition, Wilkin County should consider providing further training to program personnel. View of Responsible Official: Concur
2024-008 Suspension and Debarment Prior Year Finding Number: 2023-002 Year of Finding Origination: 2023 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of the Treasury Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: SLFRP2411; 2021 Pass-Through Agency: N/A – Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction. Condition: For the two covered transactions tested, the County did not maintain documentation of verification that the vendors were not suspended or debarred prior to entering into the covered transactions. Questioned Costs: $187,679; known questioned costs were determined based on payments to the two vendors tested. Context: During the year, the County entered into three covered transactions using COVID-19 – Coronavirus State and Local Fiscal Recovery Funds. The covered transactions totaled $222,953. The sample size was based on the guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Failure to verify vendors are not suspended, debarred, or otherwise excluded prior to entering into a covered transaction may result in the County entering into a transaction with a vendor that is not authorized to provide goods and services under the grant. Cause: The County indicated significant staff turnover in key positions. The previous staff were not available to locate the documentation. Recommendation: We recommend the County maintain documentation to demonstrate that vendors were not debarred, suspended, or otherwise excluded from conducting business with the County; the County should complete this documentation prior to entering into a covered transaction. View of Responsible Official: Concur
2024-006 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting Prior Year Finding Number: N/A Year of Finding Origination: 2024 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Material Weakness and Modified Opinion Federal Agency: U.S. Department of Health and Human Services Program: 93.778 Grants to States for Medicaid Award Number and Year: 2405MN5ADM; 2024 Pass-Through Agency: Minnesota Department of Human Services Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 2 U.S. Code of Federal Regulations §§ 200.403(a) and 200.403(g) require costs to be necessary and reasonable, and be adequately documented. For federal awards received from the Minnesota Department of Human Services (DHS), internal controls should be established and maintained to provide assurance that program reports submitted to DHS are completed and documented in accordance with DHS reporting instructions. As part of Wilkin County’s reporting requirements, the Public Health Department submits the Local Collaborative Time Study (LCTS) Public Health Cost Schedule DHS-3220.3 on a quarterly basis. Condition: The County did not maintain adequate support for the reported payroll amounts on LCTS Public Health Cost Schedule DHS-3220.3 reports tested. The reports also had no documentation of review. Questioned Costs: $329,183; known questioned costs were determined based on the payroll costs from each of the four LCTS Public Health Cost Schedule DHS-3220.3 reports. Context: Minnesota DHS relies on accurate submission of program costs to ensure that resulting grant funds paid to Wilkin County are for applicable federal program activities/costs. Total expenditures reported on the Schedule of Expenditures of Federal Awards are $416,193. Amounts reported on the DHS-2550, DHS-2556, and LCTS Public Health Cost Schedule DHS-3220.3 reports were $759,694, $1,879,054, and $379,254, respectively. The State of Minnesota determines the reimbursement of reported expenditures. The reporting population consisted of four quarterly DHS-2550, DHS-2556, and LCTS Public Health Cost Schedule DHS-3220.3 reports; and originally a sample of two of each report type was selected for report testing. Additionally, a sample of 40 expenditures were selected for testing, which included five LCTS Public Health Cost Schedule DHS-3220.3 expenditures for testing. Payroll reported expenditure testing relating to the LCTS Public Health Cost Schedule DHS-3220.3 was expanded to cover payroll expenditures of all four quarters.The sample size was based on the guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits, and subsequently expanded. Effect: Errors in the identification and reporting of costs on the quarterly reports can impair DHS’ ability to provide required oversight over federal programs and result in the County receiving either more or less federal funds than justified based on the actual underlying activity. Cause: The employee who prepared the reports and the supporting documentation left the County in 2025. The supporting documentation could not be located. Recommendation: We recommend the County implement controls to ensure activities allowed and allowable costs are appropriately identified and accurately reported to DHS in accordance with federal program guidance and DHS instructions, including that reports are reviewed by someone other than the preparer. We also recommend the County correct and resubmit reports submitted with unallowable activities or costs, costs allocated incorrectly, or activity reporting incorrectly. View of Responsible Official: Concur
2024-009 Reporting Prior Year Finding Number: N/A Year of Finding Origination: 2024 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Material Weakness and Modified Opinion Federal Agency: U.S. Department of the Treasury Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: SLFRP2411; 2021 Pass-Through Agency: N/A – Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The U.S. Department of the Treasury requires recipients of funds to submit Project and Expenditure Reports that include, by project, current period obligations, cumulative obligations, current period expenditures, and cumulative expenditures. The frequency of reporting is dependent on the size of the entity and amount of funding received. Condition: The County understated current period expenditures reported, and cumulative expenditures reported on the annual Project and Expenditure Report submitted to the U.S. Department of the Treasury by $182,285. Also, the County did not submit the annual Project and Expenditure Report by the federal deadline of April 30, 2024. Questioned Costs: None. Context: The County opted to spend the COVID-19 – Coronavirus State and Local Fiscal Recovery Funds award under the Revenue Replacement category, which allows spending on broader types of government services. The annual Project and Expenditure Report required to be submitted to the U.S. Department of the Treasury by April 30 of each year for the reporting period ending March 31 was submitted August 14, 2024. Effect: The County is not in compliance with federal reporting requirements. Cause: The County indicated difficulty tracking project expenditures due to staff turnover. Recommendation: We recommend the County review the U.S. Department of the Treasury’s guidance and form instructions to ensure accurate reporting of COVID-19 – Coronavirus State and Local Fiscal Recovery Funds activity. We also recommend the County submit future Project and Expenditure Reports by the federal deadline. View of Responsible Official: Concur
Condition: During our testing of allowable activities/cost and period of performance it was noted the Organization did not perform or document required approval/review over expenditures. Criteria: Per § 200.303 of the Code of Federal Regulations, recipients must establish, document, and maintain internal controls over Federal awards that provides reasonable assurance that the recipient is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Organization lacked formal policies and procedures to ensure documentation and performance of approval/review over expenditures and applications. The responsibility for oversight along with monitoring activities was not documented. Effect: Failure to establish, document, and maintain internal controls increases the risk that federal funds may not be used in accordance with applicable laws and regulations, potentially resulting in noncompliance with program requirements. Context: This condition was identified in all sampled populations of allowable activities/cost and period of performance. This finding is a repeat finding of the immediate prior audit. Reference number includes 2023-004. Recommendation: We recommend the Organization develop and implement formal documented review/approval and monitoring procedures which include the written or electronic signature of authorized individuals on invoices. Management has noted that they have implemented procedures beginning in 2025 to address this finding. Views of Responsible Officials: Management agrees with the finding.
Finding 2024-001 Audit Delays Federal Agencies: U.S. Department of State and U.S. Agency for International Development Federal Programs: International Programs to Support Democracy, Human Rights and Labor and Foreign Assistance for Programs Overseas Assistance Listing Numbers: 19.345 and 98.001 Pass-through Entity: None Award Identification Number and Year: S-LMAQM-20-GR-2099, S-LMAQM-20-GR-2100, SAQMIP- 22-GR-0005, S-AQMIP-23-GR-0343, 720-523-18-CA-00006, 720-486-23-LA-00001 Criteria or Specific Requirement: As noted in 2 CFR §200.303 "The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)". As noted in 2 CFR §200.512 the audit report should be submitted nine months after the end of the audit period. Condition: There were delays in performing the audit, resulting in a late filing of the Uniform Guidance audit. In addition, we noted that certain accounts had not been reconciled throughout the year, but instead as part of audit preparation only. We noted that reconciliation of the indirect rate had also been delayed due to late receipt of a final rate and that further analysis is pending to determine any adjustments that may be required from the final rate determination. Cause: The above conditions arose due to numerous factors, including transition and turnover within the accounting department. Effect or Potential Effect: Timely year-end closure is important to avoid increased potential for fraud, misstatements, and failures to adhere to donor and other regulations. Effective filing of documents decreases the potential for non-compliance with donor requirements, questioned costs or findings. Questioned Costs: None Context: ICFJ has been impacted by funding changes as well as transition in staff within the acconting department. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: We recommend that ICFJ ensure that a monthly close process is followed to ensure timely and accurate financial reporting, transparent documentation of review and approval of transactions, and compliance with applicable donor requirements. Financial and compliance documents should be filed to permit prompt retrieval.
Finding 2024-004 Cash Management Federal Agencies: U.S. Department of State and U.S. Agency for International Development Federal Programs: International Programs to Support Democracy, Human Rights and Labor and Foreign Assistance for Programs Overseas Assistance Listing Numbers: 19.345 and 98.001 Pass-through Entity: None Award Identification Number and Year: S-LMAQM-20-GR-2099, S-LMAQM-20-GR-2100, SAQMIP- 22-GR-0005, S-AQMIP-23-GR-0343, 720-523-18-CA-00006, 720-486-23-LA-00001 Criteria or Specific Requirement: Under 2 CFR 200.303, organizations that receive Federal funding are required 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 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: Evidence of review/approval for certain drawdown requests could not be provided. The supporting documentation for certain requests (i.e. the schedule documenting the calculation for the amount requested) was also not available. While management asserts that a review and approval of drawdown requests occurred, there is no audit trail that shows the evidence of the control occurring. Cause: ICFJ experienced transition during the fiscal year and certain documents were unable to be located during the audit process. Effect or Potential Effect: Appropriate procedures and documentation for drawdown requests is important to ensure compliance with cash management compliance requirements. Questioned Costs: None Context: Our audit procedures consisted of testwork performed over cash receipts and drawdown requests from the Federal Government. We consider our sample to be representative of the population. The condition appears to be systemic in nature. Identification as a Repeat Finding, if Applicable: This is a repeat finding (2023-004) Recommendation: We recommend that management of ICFJ implement procedures and control processes to incorporate and document an independent review and approval, evidenced by a signature/initialing and date of the review and approval taking place prior to submission to the funder. Each request should be filed with the documentation supporting the calculation of the request.
Criteria: In accordance with 2 CFR §200.303, the auditee must establish and maintain effective internal control over federal awards to provide reasonable assurance that expenditures are properly recorded and reported in compliance with applicable laws, regulations, and the terms and conditions of the award. Condition: During testing of allowability, we identified instances in which expenditures were coded to incorrect accounts within the general ledger. Cause: Based on inquiry with management, the errors occurred due to the implementation of new accounting software during the year under audit, which resulted in inconsistencies in account mapping and user understanding of the updated chart of accounts. Effect: Improper coding of expenditures increases the risk that costs may be misclassified or reported incorrectly on financial reports and federal schedules, including the SEFA. This could lead to noncompliance with federal reporting requirements and reduce the reliability of financial information used for decision-making. Recommendation: We recommend that management strengthen internal controls over financial reporting by (1) providing additional training to personnel on the updated accounting system and chart of accounts, (2) implementing a review process to verify proper coding of expenditures, particularly following system changes, and (3) performing periodic reconciliations and monitoring procedures to detect and correct misclassifications in a timely manner. Foundation Response: Management agrees with the finding.