Material Weakness in Internal Control Over Compliance – G. Matching, Level of Effort, Earmarking Criteria: 2 CFR 200.303 includes requirements related to internal controls for federal award programs, including that the Organization must, among other things, “establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 and Context: During 2023, the Organization reconciled the applicable match at the end of the grant period and submitted to the City of Indianapolis. There was no documentation on review of the schedule of the match nor was there a periodic assessment of the match until the reporting date. Cause and Effect: We noted a lack of internal controls surrounding the tracking and review of the match. Errors could have occurred in the annual grant matching report which could have resulted in material non-compliance. Recommendation: We recommend the Organization implement procedures to track the match on a monthly basis with adequate review and approval. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the recommendation and plans to implement a formal review expenditures of federal awards corrective action by December 31, 2024.
Material Weakness in Internal Control Over Compliance – G. Matching, Level of Effort, Earmarking Criteria: 2 CFR 200.303 includes requirements related to internal controls for federal award programs, including that the Organization must, among other things, “establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 and Context: During 2023, the Organization reconciled the applicable match at the end of the grant period and submitted to the City of Indianapolis. There was no documentation on review of the schedule of the match nor was there a periodic assessment of the match until the reporting date. Cause and Effect: We noted a lack of internal controls surrounding the tracking and review of the match. Errors could have occurred in the annual grant matching report which could have resulted in material non-compliance. Recommendation: We recommend the Organization implement procedures to track the match on a monthly basis with adequate review and approval. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the recommendation and plans to implement a formal review expenditures of federal awards corrective action by December 31, 2024.
Material Weakness in Internal Control Over Compliance – G. Matching, Level of Effort, Earmarking Criteria: 2 CFR 200.303 includes requirements related to internal controls for federal award programs, including that the Organization must, among other things, “establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 and Context: During 2023, the Organization reconciled the applicable match at the end of the grant period and submitted to the City of Indianapolis. There was no documentation on review of the schedule of the match nor was there a periodic assessment of the match until the reporting date. Cause and Effect: We noted a lack of internal controls surrounding the tracking and review of the match. Errors could have occurred in the annual grant matching report which could have resulted in material non-compliance. Recommendation: We recommend the Organization implement procedures to track the match on a monthly basis with adequate review and approval. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the recommendation and plans to implement a formal review expenditures of federal awards corrective action by December 31, 2024.
FINDING 2023-003 Subject: CDBG - Entitlement Grants Cluster - Internal Control Federal Agency: Department of Housing and Urban Development Federal Programs: Community Development Block Grants/Entitlement Grants; COVID-19 - Community Development Block Grants/Entitlement Grants Assistance Listings Number: 14.218 Federal Award Numbers and Years (or Other Identifying Numbers): B20MC180005; B21MC180005; B22MC180005; B20MW180005 Compliance Requirement: Reporting Audit Finding: Material Weakness INDIANA STATE BOARD OF ACCOUNTS 23 CITY OF GARY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context Recipients are required to submit quarterly the CDBG Cash on Hand Quarterly report (PR29). The report is generated from information entered by the City into the HUD's Integrated Disbursement Information System (IDIS). Recipients are also required to submit annually a Section 3 Summary Report and Federal Funding Accountability and Transparency Act (FFATA) reports. The City did not have internal control procedures in place over the PR29 quarterly reports, Section 3 Summary Report, and the FFATA Report. The reports were generated and submitted by one individual, without a review or oversight process to detect and correct errors prior to submission. The lack of internal controls was isolated to the reports 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). . . ." Cause A proper system of internal controls was not designed or implemented by management of the City to ensure that policies and procedures were in place related to reporting to ensure the amounts reported were accurate. Effect Without the proper implementation of an effectively designed system of internal controls over reporting, the City cannot ensure that the reports submitted are materially accurate and correct. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the management of the City design and implement a proper system of internal controls, including a segregation of duties, to ensure the accuracy and correctness of the PR 29 reports, Section 3 Summary Report, and FFATA Reports. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003 Subject: CDBG - Entitlement Grants Cluster - Internal Control Federal Agency: Department of Housing and Urban Development Federal Programs: Community Development Block Grants/Entitlement Grants; COVID-19 - Community Development Block Grants/Entitlement Grants Assistance Listings Number: 14.218 Federal Award Numbers and Years (or Other Identifying Numbers): B20MC180005; B21MC180005; B22MC180005; B20MW180005 Compliance Requirement: Reporting Audit Finding: Material Weakness INDIANA STATE BOARD OF ACCOUNTS 23 CITY OF GARY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context Recipients are required to submit quarterly the CDBG Cash on Hand Quarterly report (PR29). The report is generated from information entered by the City into the HUD's Integrated Disbursement Information System (IDIS). Recipients are also required to submit annually a Section 3 Summary Report and Federal Funding Accountability and Transparency Act (FFATA) reports. The City did not have internal control procedures in place over the PR29 quarterly reports, Section 3 Summary Report, and the FFATA Report. The reports were generated and submitted by one individual, without a review or oversight process to detect and correct errors prior to submission. The lack of internal controls was isolated to the reports 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). . . ." Cause A proper system of internal controls was not designed or implemented by management of the City to ensure that policies and procedures were in place related to reporting to ensure the amounts reported were accurate. Effect Without the proper implementation of an effectively designed system of internal controls over reporting, the City cannot ensure that the reports submitted are materially accurate and correct. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the management of the City design and implement a proper system of internal controls, including a segregation of duties, to ensure the accuracy and correctness of the PR 29 reports, Section 3 Summary Report, and FFATA Reports. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Internal Control Over Compliance Information on Federal Program: U.S. Department of Health COVID-19 Detection and Mitigation of COVID-19 in Confinement Facilities, federal assistance listing number 93.323. Criteria: 2 CFR Section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards incompliance with federal statutes, regulations, and the terms and conditions of the federal awards. Statement of Condition: Adequate internal controls over compliance are not established. Specifically, there is a lack of segregation of duties. Statement of Cause: Segregation of these duties has not been achieved due to the small size of the Association and current procedures. Statement of Effect: The New York State Sheriffs’ Association, Inc. is not in compliance with 2 CFR Section 200.303. There is a reasonable possibility that noncompliance would not be prevented or detected and corrected in a timely basis. Questioned Cost: None Repeat Finding: Yes Perspective Information: Management did have a process to identify and track costs under the grant through the use of separate general ledger accounts for purposes of claiming reimbursement. Recommendation: We recommend a review of policies and procedures to update and determine where changes may provide opportunities for segregation of duties. Views of responsible officials and planned corrective actions: Invoices received by NYSSA pertaining to Federal Grants will be given to the Deputy Director, Lucas Ashby for review. (current procedure). Invoices to be paid will be entered into Quickbooks financial software by the Finance Manager, Jon Greenwalt (current procedure). Checks for payment to grant vendors follow the same procedures and processes as listed in 2022-001 above, numbers 1 and 2 [New procedure implemented] Based on the timeline of the 2022 audit, many of the corrective actions were made in late Oct/November 2023.
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: SLFRP1045 - 2021 Pass-Through Agency: City of Seattle Pass-Through Number(s): DC222308 Award Period: 4/1/2022 to 3/31/2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: 2 CFR 200.303 of the Uniform Guidance states the recipient of Federal awards must 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. These internal controls should align with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework" issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Controls over expenditure approval were not being consistently applied. Questioned costs: $3,781 Context: Of the 29 general disbursements tested, 5 expenditures did not show evidence of approval Cause: Likely caused by an administrative oversight or error. Effect: Potential outcome would be an unallowable cost being charged to the Federal program. Repeat finding: No Recommendation: We recommend that approval of all expenditures, whether initiated by an invoice or a journal entry be documented. In the case where the expenditure is likely to be charged to a Federal program, it is recommended there be documentation of approval from someone knowledgeable of allowability of costs (it is permissible if this is the same individual as the initial approver). Views of responsible officials: There is no disagreement with the audit finding.
Item 2023-001 – Special Test and Provision – Wage Rate Requirement – Material Weakness in Internal Controls over Compliance/Material Noncompliance ALN and Title: 84.425C COVID-19 Education Stabilization Fund- Governor’s Emergency Education Relief (GEER) Fund II Pass-Through Entity: AL State Department of Education Contract/Grant Number- S425C210030 Award Year: 2023 Condition - The Organization did not ensure contractor contracts had required language related to Wage Rate Requirements and did not maintain weekly certified payrolls. Criteria - Per Title 2 US Code of Federal Regulations Part 200.303a, 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. Per Title 2 US Code of Federal Regulations Appendix II to Part 200, all contracts made by the non- Federal entities under the federal award must contain provisions covering the following, (D) Davis- Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all Prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146–3148) as supplemented by Department of Labor regulations (29 CFR Part 5, “Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction”). Questioned Costs - Actual and likely questioned costs are undetermined. Effect - The Organization was not aware of the project falling under the Wage Rate Requirements and did not ensure contracts included the required language and ensure certified payrolls were obtained weekly. Originally the contract was not Federal funded, and the requirement was overlooked when the determination was made to use GEER Fund II funding for the project. Cause - The Organization could enter into a contract agreement with contractors who are not familiar with the Davis-Bacon act and not follow requirements to pay laborers a prevailing wage weekly. This could lead to disallowed costs charged to the grant and/or repayment to the Grantor agency. Auditor’s Recommendation - The auditor recommends the Organization strengthen the controls in place to provide assurance that contract agreements entered into with subcontractors contain the required clauses set by the Davis-Bacon act and projects that fall under the requirement maintain the weekly certified payrolls. Views of Responsible Officials and Planned Corrective Action - The Organization’s current Business Office management is aware of the noncompliance of the Davis-Bacon Act wage rate requirement. We understand the importance of implementing sound internal controls to ensure the Organization meets all federal and state compliance requirements. In order to prevent future noncompliance findings, the Organization will implement staff trainings to ensure full adherence to all applicable federal and state compliance requirements. In addition, the Organization will increase oversight over federal grant programs. Responsible Official – Ben Rogers, Director of Operations Timeline and Estimated Completion Date – December 31,2024
Federal Program Information: Funding Agency: The Corporation for National and Community Service Title: Foster Grandparent/Senior Companion Cluster Assistance Listing Number: 94.011, 94.016 Federal Award Identification number 22SFHFK002, 22SCHFL001 Award Year: 2023 Condition: Based on audit procedures performed, it was determined there were instances that review and approval in internal controls related to the annual income verification had not been documented. The Organization lacks controls over compliance for eligibility for volunteers for annual income verification that would ensure review and approval of eligibility of program volunteers on an annual basis. Criteria: Per 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Per 45 CFR Part 2551 Subpart D and 45 CFR Part 2552 Subpart D, participants in the Senior Companion/Foster Grandparent Cluster must meet certain income eligibility guidelines, which are updated annually. Questioned costs: No questioned costs. Effect: The Organization could spend federal award monies on stipends provided to ineligible volunteers that would not be detected by controls that are not operating. Cause: The Organization’s staff did not follow eligibility review procedures to ensure the annual review of income eligibility is completed and reviewed. Auditor’s Recommendation: The Auditor recommends the Organization provide training for all program staff for eligibility review procedures and the requirements of document retention and documentation of review and approval. Views of Responsible Officials and Planned Corrective Action: See Management’s Response and Corrective Action Plan beginning on page 47.
Federal Program Information: Funding Agency: The Corporation for National and Community Service Title: Foster Grandparent/Senior Companion Cluster Assistance Listing Number: 94.011, 94.016 Federal Award Identification number 22SFHFK002, 22SCHFL001 Award Year: 2023 Condition: Based on audit procedures performed, it was determined there were instances that review and approval in internal controls related to the annual income verification had not been documented. The Organization lacks controls over compliance for eligibility for volunteers for annual income verification that would ensure review and approval of eligibility of program volunteers on an annual basis. Criteria: Per 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Per 45 CFR Part 2551 Subpart D and 45 CFR Part 2552 Subpart D, participants in the Senior Companion/Foster Grandparent Cluster must meet certain income eligibility guidelines, which are updated annually. Questioned costs: No questioned costs. Effect: The Organization could spend federal award monies on stipends provided to ineligible volunteers that would not be detected by controls that are not operating. Cause: The Organization’s staff did not follow eligibility review procedures to ensure the annual review of income eligibility is completed and reviewed. Auditor’s Recommendation: The Auditor recommends the Organization provide training for all program staff for eligibility review procedures and the requirements of document retention and documentation of review and approval. Views of Responsible Officials and Planned Corrective Action: See Management’s Response and Corrective Action Plan beginning on page 47.
Federal Program Information: Funding Agency: The Corporation for National and Community Service Title: Foster Grandparent/Senior Companion Cluster Assistance Listing Number: 94.011, 94.016 Federal Award Identification number 22SFHFK002, 22SCHFL001 Award Year: 2023 Condition: Based on audit procedures performed, it was determined that internal controls related to the review and approval of semi-annual programmatic reports had not been documented. Criteria: Per 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Questioned costs: No questioned costs. Effect: The Organization could unknowingly submit inaccurate information to the Grantor. Cause: The Organization does not have internal controls in place to ensure the review and approval of the programmatic semi-annual reports prior to submission. Auditor’s Recommendation: The Auditor recommends the Organization develop and implement adequate internal controls to ensure reporting is reviewed for accuracy and approval is documented prior to submission. Views of Responsible Officials and Planned Corrective Action: See Management’s Response and Corrective Action Plan beginning on page 47.
Federal Program Information: Funding Agency: The Corporation for National and Community Service Title: Foster Grandparent/Senior Companion Cluster Assistance Listing Number: 94.011, 94.016 Federal Award Identification number 22SFHFK002, 22SCHFL001 Award Year: 2023 Condition: Based on audit procedures performed, it was determined that internal controls related to the review and approval of semi-annual programmatic reports had not been documented. Criteria: Per 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Questioned costs: No questioned costs. Effect: The Organization could unknowingly submit inaccurate information to the Grantor. Cause: The Organization does not have internal controls in place to ensure the review and approval of the programmatic semi-annual reports prior to submission. Auditor’s Recommendation: The Auditor recommends the Organization develop and implement adequate internal controls to ensure reporting is reviewed for accuracy and approval is documented prior to submission. Views of Responsible Officials and Planned Corrective Action: See Management’s Response and Corrective Action Plan beginning on page 47.
FINDING 2023-002 – Reporting, Non-compliance (Significant Deficiency) Federal program: All programs Criteria: 2 CFR Part 200.303(a) 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 terms and conditions of the federal award. Section 200.512 of the Uniform Guidance states that the single audit shall be completed and reporting submitted within the earlier of 30 calendar days after receipt of the auditors’ report or nine months after the end of the fiscal year unless a longer period is specified. Condition and Context: The Organization did not complete and submit its audit report prior to the required deadline. Cause and Effect: Due to a delay in the compiling of records related to the audit, the Organization was not in compliance with the reporting requirements. Questioned costs: None Repeat finding: Yes
FINDING 2023-002 – Reporting, Non-compliance (Significant Deficiency) Federal program: All programs Criteria: 2 CFR Part 200.303(a) 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 terms and conditions of the federal award. Section 200.512 of the Uniform Guidance states that the single audit shall be completed and reporting submitted within the earlier of 30 calendar days after receipt of the auditors’ report or nine months after the end of the fiscal year unless a longer period is specified. Condition and Context: The Organization did not complete and submit its audit report prior to the required deadline. Cause and Effect: Due to a delay in the compiling of records related to the audit, the Organization was not in compliance with the reporting requirements. Questioned costs: None Repeat finding: Yes
FINDING 2023-002 – Reporting, Non-compliance (Significant Deficiency) Federal program: All programs Criteria: 2 CFR Part 200.303(a) 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 terms and conditions of the federal award. Section 200.512 of the Uniform Guidance states that the single audit shall be completed and reporting submitted within the earlier of 30 calendar days after receipt of the auditors’ report or nine months after the end of the fiscal year unless a longer period is specified. Condition and Context: The Organization did not complete and submit its audit report prior to the required deadline. Cause and Effect: Due to a delay in the compiling of records related to the audit, the Organization was not in compliance with the reporting requirements. Questioned costs: None Repeat finding: Yes
Program: Continuum of Care, Emergency Solutions Grant Program Federal Financial Assistance Listing No.:14.267, 14.231 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: Sacramento Steps Forward, Sacramento County Department of Human Assistance Award Year: 2023 Compliance Requirement: Procurement, Suspension and Debarment Grant Award Number: CA0955L9T032108, CA0955L9T032209, CA0143L9T032114, CA0143L9T032215, CA1303L9T032107, CA1303L9T032208, DHA-NM-03-23, DHA-NM-03-24 Type of Finding: Material Weakness in Internal Controls Over Compliance Criteria: 2 CFR 200.303(a) of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The nonfederal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are met. As outlined in 2 CFR 180, recipients must not utilize any contractor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition Found: The Organization’s procurement policy did not include all the required elements as outlined in the Uniform Guidance. Additionally, the Organization did not retain documentation to support the procedures performed to ensure compliance with suspension and debarment requirements. Cause: The Organization does not typically receive federal financial assistance that is subject to procurement and suspension and debarment regulations; consequently, certain elements required by the Uniform Guidance were missing. Effect: Lack of complete procurement, suspension, and debarment policies and not retaining documentation to support compliance with suspension and debarment requirements could result in noncompliance with Uniform Guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/ Sampling: Suspension and debarment was applicable to 9 contractors totaling $1,989,106 under the Continuum of Care Program and three contractors totaling $227,772 under the Emergency Solutions Grant Program. We tested all contractors with total payments exceeding $25,000 during the year. Repeat Finding from Prior Years: Yes, Finding 2022-03. Recommendation: We recommend that management develop a written procurement policy that conforms with Uniform Guidance. In addition, we recommend that management implement procedures and control processes to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Continuum of Care, Emergency Solutions Grant Program Federal Financial Assistance Listing No.:14.267, 14.231 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: Sacramento Steps Forward, Sacramento County Department of Human Assistance Award Year: 2023 Compliance Requirement: Procurement, Suspension and Debarment Grant Award Number: CA0955L9T032108, CA0955L9T032209, CA0143L9T032114, CA0143L9T032215, CA1303L9T032107, CA1303L9T032208, DHA-NM-03-23, DHA-NM-03-24 Type of Finding: Material Weakness in Internal Controls Over Compliance Criteria: 2 CFR 200.303(a) of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The nonfederal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are met. As outlined in 2 CFR 180, recipients must not utilize any contractor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition Found: The Organization’s procurement policy did not include all the required elements as outlined in the Uniform Guidance. Additionally, the Organization did not retain documentation to support the procedures performed to ensure compliance with suspension and debarment requirements. Cause: The Organization does not typically receive federal financial assistance that is subject to procurement and suspension and debarment regulations; consequently, certain elements required by the Uniform Guidance were missing. Effect: Lack of complete procurement, suspension, and debarment policies and not retaining documentation to support compliance with suspension and debarment requirements could result in noncompliance with Uniform Guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/ Sampling: Suspension and debarment was applicable to 9 contractors totaling $1,989,106 under the Continuum of Care Program and three contractors totaling $227,772 under the Emergency Solutions Grant Program. We tested all contractors with total payments exceeding $25,000 during the year. Repeat Finding from Prior Years: Yes, Finding 2022-03. Recommendation: We recommend that management develop a written procurement policy that conforms with Uniform Guidance. In addition, we recommend that management implement procedures and control processes to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Continuum of Care, Emergency Solutions Grant Program Federal Financial Assistance Listing No.:14.267, 14.231 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: Sacramento Steps Forward, Sacramento County Department of Human Assistance Award Year: 2023 Compliance Requirement: Procurement, Suspension and Debarment Grant Award Number: CA0955L9T032108, CA0955L9T032209, CA0143L9T032114, CA0143L9T032215, CA1303L9T032107, CA1303L9T032208, DHA-NM-03-23, DHA-NM-03-24 Type of Finding: Material Weakness in Internal Controls Over Compliance Criteria: 2 CFR 200.303(a) of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The nonfederal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are met. As outlined in 2 CFR 180, recipients must not utilize any contractor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition Found: The Organization’s procurement policy did not include all the required elements as outlined in the Uniform Guidance. Additionally, the Organization did not retain documentation to support the procedures performed to ensure compliance with suspension and debarment requirements. Cause: The Organization does not typically receive federal financial assistance that is subject to procurement and suspension and debarment regulations; consequently, certain elements required by the Uniform Guidance were missing. Effect: Lack of complete procurement, suspension, and debarment policies and not retaining documentation to support compliance with suspension and debarment requirements could result in noncompliance with Uniform Guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/ Sampling: Suspension and debarment was applicable to 9 contractors totaling $1,989,106 under the Continuum of Care Program and three contractors totaling $227,772 under the Emergency Solutions Grant Program. We tested all contractors with total payments exceeding $25,000 during the year. Repeat Finding from Prior Years: Yes, Finding 2022-03. Recommendation: We recommend that management develop a written procurement policy that conforms with Uniform Guidance. In addition, we recommend that management implement procedures and control processes to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Continuum of Care, Emergency Solutions Grant Program Federal Financial Assistance Listing No.:14.267, 14.231 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: Sacramento Steps Forward, Sacramento County Department of Human Assistance Award Year: 2023 Compliance Requirement: Procurement, Suspension and Debarment Grant Award Number: CA0955L9T032108, CA0955L9T032209, CA0143L9T032114, CA0143L9T032215, CA1303L9T032107, CA1303L9T032208, DHA-NM-03-23, DHA-NM-03-24 Type of Finding: Material Weakness in Internal Controls Over Compliance Criteria: 2 CFR 200.303(a) of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The nonfederal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are met. As outlined in 2 CFR 180, recipients must not utilize any contractor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition Found: The Organization’s procurement policy did not include all the required elements as outlined in the Uniform Guidance. Additionally, the Organization did not retain documentation to support the procedures performed to ensure compliance with suspension and debarment requirements. Cause: The Organization does not typically receive federal financial assistance that is subject to procurement and suspension and debarment regulations; consequently, certain elements required by the Uniform Guidance were missing. Effect: Lack of complete procurement, suspension, and debarment policies and not retaining documentation to support compliance with suspension and debarment requirements could result in noncompliance with Uniform Guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/ Sampling: Suspension and debarment was applicable to 9 contractors totaling $1,989,106 under the Continuum of Care Program and three contractors totaling $227,772 under the Emergency Solutions Grant Program. We tested all contractors with total payments exceeding $25,000 during the year. Repeat Finding from Prior Years: Yes, Finding 2022-03. Recommendation: We recommend that management develop a written procurement policy that conforms with Uniform Guidance. In addition, we recommend that management implement procedures and control processes to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Continuum of Care, Emergency Solutions Grant Program Federal Financial Assistance Listing No.:14.267, 14.231 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: Sacramento Steps Forward, Sacramento County Department of Human Assistance Award Year: 2023 Compliance Requirement: Procurement, Suspension and Debarment Grant Award Number: CA0955L9T032108, CA0955L9T032209, CA0143L9T032114, CA0143L9T032215, CA1303L9T032107, CA1303L9T032208, DHA-NM-03-23, DHA-NM-03-24 Type of Finding: Material Weakness in Internal Controls Over Compliance Criteria: 2 CFR 200.303(a) of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The nonfederal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are met. As outlined in 2 CFR 180, recipients must not utilize any contractor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition Found: The Organization’s procurement policy did not include all the required elements as outlined in the Uniform Guidance. Additionally, the Organization did not retain documentation to support the procedures performed to ensure compliance with suspension and debarment requirements. Cause: The Organization does not typically receive federal financial assistance that is subject to procurement and suspension and debarment regulations; consequently, certain elements required by the Uniform Guidance were missing. Effect: Lack of complete procurement, suspension, and debarment policies and not retaining documentation to support compliance with suspension and debarment requirements could result in noncompliance with Uniform Guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/ Sampling: Suspension and debarment was applicable to 9 contractors totaling $1,989,106 under the Continuum of Care Program and three contractors totaling $227,772 under the Emergency Solutions Grant Program. We tested all contractors with total payments exceeding $25,000 during the year. Repeat Finding from Prior Years: Yes, Finding 2022-03. Recommendation: We recommend that management develop a written procurement policy that conforms with Uniform Guidance. In addition, we recommend that management implement procedures and control processes to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Continuum of Care, Emergency Solutions Grant Program Federal Financial Assistance Listing No.:14.267, 14.231 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: Sacramento Steps Forward, Sacramento County Department of Human Assistance Award Year: 2023 Compliance Requirement: Procurement, Suspension and Debarment Grant Award Number: CA0955L9T032108, CA0955L9T032209, CA0143L9T032114, CA0143L9T032215, CA1303L9T032107, CA1303L9T032208, DHA-NM-03-23, DHA-NM-03-24 Type of Finding: Material Weakness in Internal Controls Over Compliance Criteria: 2 CFR 200.303(a) of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The nonfederal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are met. As outlined in 2 CFR 180, recipients must not utilize any contractor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition Found: The Organization’s procurement policy did not include all the required elements as outlined in the Uniform Guidance. Additionally, the Organization did not retain documentation to support the procedures performed to ensure compliance with suspension and debarment requirements. Cause: The Organization does not typically receive federal financial assistance that is subject to procurement and suspension and debarment regulations; consequently, certain elements required by the Uniform Guidance were missing. Effect: Lack of complete procurement, suspension, and debarment policies and not retaining documentation to support compliance with suspension and debarment requirements could result in noncompliance with Uniform Guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/ Sampling: Suspension and debarment was applicable to 9 contractors totaling $1,989,106 under the Continuum of Care Program and three contractors totaling $227,772 under the Emergency Solutions Grant Program. We tested all contractors with total payments exceeding $25,000 during the year. Repeat Finding from Prior Years: Yes, Finding 2022-03. Recommendation: We recommend that management develop a written procurement policy that conforms with Uniform Guidance. In addition, we recommend that management implement procedures and control processes to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Continuum of Care, Emergency Solutions Grant Program Federal Financial Assistance Listing No.:14.267, 14.231 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: Sacramento Steps Forward, Sacramento County Department of Human Assistance Award Year: 2023 Compliance Requirement: Procurement, Suspension and Debarment Grant Award Number: CA0955L9T032108, CA0955L9T032209, CA0143L9T032114, CA0143L9T032215, CA1303L9T032107, CA1303L9T032208, DHA-NM-03-23, DHA-NM-03-24 Type of Finding: Material Weakness in Internal Controls Over Compliance Criteria: 2 CFR 200.303(a) of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The nonfederal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are met. As outlined in 2 CFR 180, recipients must not utilize any contractor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition Found: The Organization’s procurement policy did not include all the required elements as outlined in the Uniform Guidance. Additionally, the Organization did not retain documentation to support the procedures performed to ensure compliance with suspension and debarment requirements. Cause: The Organization does not typically receive federal financial assistance that is subject to procurement and suspension and debarment regulations; consequently, certain elements required by the Uniform Guidance were missing. Effect: Lack of complete procurement, suspension, and debarment policies and not retaining documentation to support compliance with suspension and debarment requirements could result in noncompliance with Uniform Guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/ Sampling: Suspension and debarment was applicable to 9 contractors totaling $1,989,106 under the Continuum of Care Program and three contractors totaling $227,772 under the Emergency Solutions Grant Program. We tested all contractors with total payments exceeding $25,000 during the year. Repeat Finding from Prior Years: Yes, Finding 2022-03. Recommendation: We recommend that management develop a written procurement policy that conforms with Uniform Guidance. In addition, we recommend that management implement procedures and control processes to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Continuum of Care, Emergency Solutions Grant Program Federal Financial Assistance Listing No.:14.267, 14.231 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: Sacramento Steps Forward, Sacramento County Department of Human Assistance Award Year: 2023 Compliance Requirement: Procurement, Suspension and Debarment Grant Award Number: CA0955L9T032108, CA0955L9T032209, CA0143L9T032114, CA0143L9T032215, CA1303L9T032107, CA1303L9T032208, DHA-NM-03-23, DHA-NM-03-24 Type of Finding: Material Weakness in Internal Controls Over Compliance Criteria: 2 CFR 200.303(a) of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The nonfederal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are met. As outlined in 2 CFR 180, recipients must not utilize any contractor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition Found: The Organization’s procurement policy did not include all the required elements as outlined in the Uniform Guidance. Additionally, the Organization did not retain documentation to support the procedures performed to ensure compliance with suspension and debarment requirements. Cause: The Organization does not typically receive federal financial assistance that is subject to procurement and suspension and debarment regulations; consequently, certain elements required by the Uniform Guidance were missing. Effect: Lack of complete procurement, suspension, and debarment policies and not retaining documentation to support compliance with suspension and debarment requirements could result in noncompliance with Uniform Guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/ Sampling: Suspension and debarment was applicable to 9 contractors totaling $1,989,106 under the Continuum of Care Program and three contractors totaling $227,772 under the Emergency Solutions Grant Program. We tested all contractors with total payments exceeding $25,000 during the year. Repeat Finding from Prior Years: Yes, Finding 2022-03. Recommendation: We recommend that management develop a written procurement policy that conforms with Uniform Guidance. In addition, we recommend that management implement procedures and control processes to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Finding 2023-002: Account Reconciliations and Financial Statement Close Process (Significant Deficiency) Federal Programs: All Federal programs Criteria: Under 2 CFR 200.303, Internal Controls, the Uniform Guidance requires that the grantee must: establish, document 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: The year-end schedules supporting certain asset and liability accounts were incorrectly prepared and required revision, resulting in adjustments to ICMEC's consolidated financial statements. In addition, the intercompany assets and liabilities were not reconciled. Due to the above, a significant amount of time was spent by management during the audit process reconciling various accounts which resulted in audit delays. The audit delays, in turn, resulted in additional audit work performed after the original end date of field work. Cause: ICMEC's controls are not adequately designed to ensure timely and accurate reconciliation of asset and liability accounts, including the intercompany assets and liabilities. As a result, significant adjustments were proposed by management and the auditors during the audit. Effect: Without the proper reconciliation of all accounts on a monthly basis, in a timely manner, as well as the proper review and approval of such reconciliations, there exists the potential for reporting errors and misappropriation of funds. Additionally, as a result of these delays, ICMEC did not submit its Data Collection Form in time to be in compliance with the due date of September 30, 2024. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on various asset, liability, support and revenue and expense account balances. We consider our sample and testing to be representative of the population. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that all asset and liability account reconciliations, including intercompany assets and liabilities, be performed on a monthly or quarterly (at a minimum) basis. We also recommend detailed reviews and approvals of all supporting schedules (and related consolidated financial statements) be performed and contemporaneously documented in the accounting records. Any discrepancies or other issues should be resolved in a timely manner.
Finding 2023-002: Account Reconciliations and Financial Statement Close Process (Significant Deficiency) Federal Programs: All Federal programs Criteria: Under 2 CFR 200.303, Internal Controls, the Uniform Guidance requires that the grantee must: establish, document 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: The year-end schedules supporting certain asset and liability accounts were incorrectly prepared and required revision, resulting in adjustments to ICMEC's consolidated financial statements. In addition, the intercompany assets and liabilities were not reconciled. Due to the above, a significant amount of time was spent by management during the audit process reconciling various accounts which resulted in audit delays. The audit delays, in turn, resulted in additional audit work performed after the original end date of field work. Cause: ICMEC's controls are not adequately designed to ensure timely and accurate reconciliation of asset and liability accounts, including the intercompany assets and liabilities. As a result, significant adjustments were proposed by management and the auditors during the audit. Effect: Without the proper reconciliation of all accounts on a monthly basis, in a timely manner, as well as the proper review and approval of such reconciliations, there exists the potential for reporting errors and misappropriation of funds. Additionally, as a result of these delays, ICMEC did not submit its Data Collection Form in time to be in compliance with the due date of September 30, 2024. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on various asset, liability, support and revenue and expense account balances. We consider our sample and testing to be representative of the population. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that all asset and liability account reconciliations, including intercompany assets and liabilities, be performed on a monthly or quarterly (at a minimum) basis. We also recommend detailed reviews and approvals of all supporting schedules (and related consolidated financial statements) be performed and contemporaneously documented in the accounting records. Any discrepancies or other issues should be resolved in a timely manner.
Finding 2023-002: Account Reconciliations and Financial Statement Close Process (Significant Deficiency) Federal Programs: All Federal programs Criteria: Under 2 CFR 200.303, Internal Controls, the Uniform Guidance requires that the grantee must: establish, document 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: The year-end schedules supporting certain asset and liability accounts were incorrectly prepared and required revision, resulting in adjustments to ICMEC's consolidated financial statements. In addition, the intercompany assets and liabilities were not reconciled. Due to the above, a significant amount of time was spent by management during the audit process reconciling various accounts which resulted in audit delays. The audit delays, in turn, resulted in additional audit work performed after the original end date of field work. Cause: ICMEC's controls are not adequately designed to ensure timely and accurate reconciliation of asset and liability accounts, including the intercompany assets and liabilities. As a result, significant adjustments were proposed by management and the auditors during the audit. Effect: Without the proper reconciliation of all accounts on a monthly basis, in a timely manner, as well as the proper review and approval of such reconciliations, there exists the potential for reporting errors and misappropriation of funds. Additionally, as a result of these delays, ICMEC did not submit its Data Collection Form in time to be in compliance with the due date of September 30, 2024. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on various asset, liability, support and revenue and expense account balances. We consider our sample and testing to be representative of the population. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that all asset and liability account reconciliations, including intercompany assets and liabilities, be performed on a monthly or quarterly (at a minimum) basis. We also recommend detailed reviews and approvals of all supporting schedules (and related consolidated financial statements) be performed and contemporaneously documented in the accounting records. Any discrepancies or other issues should be resolved in a timely manner.
Federal Program – Community Development Block Grant Program (Assistance Listing No. 14.218), U.S. Department of Housing and Urban Development. Condition – During the testing of the Federal Funding Accountability and Transparency Act (FFATA) compliance requirement under the Community Development Block Grant Program (ALN 14.218), one report tested was not filed timely. Criteria – 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Part 170 requires subawards to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). Cause – The untimely filing of the FFATA report was due to an oversight and not having this requirement as part of written procedures. Effect – Compliance with the reporting requirement for this program is not being met and the information is not being provided on the public website. Repeat finding – Yes, Finding 2022-002 Recommendation – We recommend that the City continue with the process implemented during the fiscal year, that includes tracking the timely submission of the FFATA reports. Management’s Response (Unaudited) – The Community Development staff is in the process of preparing all outstanding FFATA reports and is developing a compliance checklist to ensure that these reports are filed timely. Corrective Action Plan (Unaudited) – The Community Development staff will create a checklist to ensure that these reports are filed timely once the agreements with the subrecipients have been approved.
Federal Program – Community Development Block Grant Program (Assistance Listing No. 14.218), U.S. Department of Housing and Urban Development. Condition – During the testing of the Federal Funding Accountability and Transparency Act (FFATA) compliance requirement under the Community Development Block Grant Program (ALN 14.218), one report tested was not filed timely. Criteria – 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Part 170 requires subawards to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). Cause – The untimely filing of the FFATA report was due to an oversight and not having this requirement as part of written procedures. Effect – Compliance with the reporting requirement for this program is not being met and the information is not being provided on the public website. Repeat finding – Yes, Finding 2022-002 Recommendation – We recommend that the City continue with the process implemented during the fiscal year, that includes tracking the timely submission of the FFATA reports. Management’s Response (Unaudited) – The Community Development staff is in the process of preparing all outstanding FFATA reports and is developing a compliance checklist to ensure that these reports are filed timely. Corrective Action Plan (Unaudited) – The Community Development staff will create a checklist to ensure that these reports are filed timely once the agreements with the subrecipients have been approved.
Federal Program – Community Development Block Grant Program (Assistance Listing No. 14.218), U.S. Department of Housing and Urban Development. Condition – During the testing of the Federal Funding Accountability and Transparency Act (FFATA) compliance requirement under the Community Development Block Grant Program (ALN 14.218), one report tested was not filed timely. Criteria – 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Part 170 requires subawards to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). Cause – The untimely filing of the FFATA report was due to an oversight and not having this requirement as part of written procedures. Effect – Compliance with the reporting requirement for this program is not being met and the information is not being provided on the public website. Repeat finding – Yes, Finding 2022-002 Recommendation – We recommend that the City continue with the process implemented during the fiscal year, that includes tracking the timely submission of the FFATA reports. Management’s Response (Unaudited) – The Community Development staff is in the process of preparing all outstanding FFATA reports and is developing a compliance checklist to ensure that these reports are filed timely. Corrective Action Plan (Unaudited) – The Community Development staff will create a checklist to ensure that these reports are filed timely once the agreements with the subrecipients have been approved.
Federal Program – Community Development Block Grant Program (Assistance Listing No. 14.218), U.S. Department of Housing and Urban Development. Condition – During the testing of the Federal Funding Accountability and Transparency Act (FFATA) compliance requirement under the Community Development Block Grant Program (ALN 14.218), one report tested was not filed timely. Criteria – 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Part 170 requires subawards to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). Cause – The untimely filing of the FFATA report was due to an oversight and not having this requirement as part of written procedures. Effect – Compliance with the reporting requirement for this program is not being met and the information is not being provided on the public website. Repeat finding – Yes, Finding 2022-002 Recommendation – We recommend that the City continue with the process implemented during the fiscal year, that includes tracking the timely submission of the FFATA reports. Management’s Response (Unaudited) – The Community Development staff is in the process of preparing all outstanding FFATA reports and is developing a compliance checklist to ensure that these reports are filed timely. Corrective Action Plan (Unaudited) – The Community Development staff will create a checklist to ensure that these reports are filed timely once the agreements with the subrecipients have been approved.
epartment of Health and Human Services Federal Financial Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 5 TIN# 910171250 Activities Allowed or Unallowed, Allowable Cost/Cost Principles Material Weakness in Internal Control over Compliance and Noncompliance Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: Confluence Health claimed and reported expenditures that contained errors based upon the underlying documentation. Cause: Confluence Health did not have adequate internal controls policy in place to ensure expenditures claimed were accurate and based upon underlying records. Effect: There is a potential that significant costs may be claimed and reported may not be supported during a subsequent examination. Questioned Costs: $89,582. Context: A nonstatistical sample of 60, supplies, services, and payroll transactions out of a population of approximately 5,215 totaling $5,006,903 were selected for testing. The sample contained errors in two transactions in which the amounts claimed on the Period 5 report were not supported by payroll records. The amounts claimed not supported by payroll records totaled $89,582 out of a total sample value of $2,615,445. Repeat Finding from Prior Years: No. Recommendation: We recommend that management modify internal control policies to ensure amounts claimed for this program agree to underlying documentation. Views of Responsible Officials: Management agrees with the finding.
Information on the federal program _ Assistance Listing Number 93.224/93.527; Health Center Program Cluster; Department of Health and Human Services; Federal Award No. H8FCS41441 for project period April 1, 2021 through December 31, 2023. Criteria or specific requirement – Activities Allowed/Unallowed and Cost Principles; As stated in 2 CFR §200.303, the non-federal entity (i.e., the Organization) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition – The Organization was unable to provide supporting documentation (i.e., invoices, contracts, etc.) for 4 expenditures charged to the federal program. Cause – The Organization did not consistently follow the internal control policies and procedures that it has in place to ensure each expenditure is supported with corroborating documentation. Effect or potential effect – There is a risk of misappropriation or charging unallowable expenditures to the program, resulting in actual and/or potential questioned costs. Questioned costs – $25,326 Context – Out of a population of 483 direct costs, a sample of 25 expenditures were selected for testing, and 4 did not have supporting documentation. The sample was not statistically valid. Identification as a repeat finding, if applicable – Is a repeat finding (2022-006) Recommendation – we recommend an individual with knowledge of the federal program review expenditures charged to the federal program and ensure all transactions are supported by documentation evidencing the nature and business purpose of each expenditure. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program _ Assistance Listing Number 10.557, Special Supplemental Nutrition Program for Women, Infants, and Children, Department of Agriculture; Assistance Listing Number 93.676, Unaccompanied Alien Children Program, Department of Health and Human Services; Assistance Listing Number 93.870, Maternal, Infant and Early Childhood Home Visiting Grant Program, Department of Health and Human Services Criteria or specific requirement – As stated in 2 CFR §200.303, the non-federal entity (i.e., the Organization) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.414 Subpart F, Appendix IV, Section C.2.f, the provisional and final rates must be negotiated where neither predetermined nor fixed rates are appropriate. Predetermined or fixed rates may replace provisional rates at any time prior to the close of the organization's fiscal year. If that event does not occur, a final rate will be established and upward or downward adjustments will be made based on the actual allowable costs incurred for the period involved. Condition – During our review of the Organization’s indirect cost rate calculation, we were unable to be provided with a true-up of actual indirect costs based on the final rates versus the provisional rates used by the Organization. Cause – The Organization did not have internal controls in place to ensure that the provisional rate utilized was in line with actual allowable costs incurred for the period involved. Effect or potential effect – Total indirect costs charged by the Organization may not be in line with the final rates determined by the oversight agency. Questioned costs – None Context – 3 out of 4 major programs tested did not have calculated indirect cost rates that agreed with their respective agreements. Identification as a repeat finding, if applicable – Is a repeat finding (2022-008) Recommendation – We recommend the Organization establish an internal control procedure to ensure that indirect costs charged to the federal program using the provisional rate are appropriately adjusted, if necessary, based on actual costs incurred. We recommend that on an annual basis, the Organization obtain an updated Nonprofit Rate Agreement from the federal government that shows final approved rates based on actual costs. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program _ Assistance Listing Number 10.557, Special Supplemental Nutrition Program for Women, Infants, and Children, Department of Agriculture; Assistance Listing Number 93.676, Unaccompanied Alien Children Program, Department of Health and Human Services; Assistance Listing Number 93.870, Maternal, Infant and Early Childhood Home Visiting Grant Program, Department of Health and Human Services Criteria or specific requirement – As stated in 2 CFR §200.303, the non-federal entity (i.e., the Organization) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.414 Subpart F, Appendix IV, Section C.2.f, the provisional and final rates must be negotiated where neither predetermined nor fixed rates are appropriate. Predetermined or fixed rates may replace provisional rates at any time prior to the close of the organization's fiscal year. If that event does not occur, a final rate will be established and upward or downward adjustments will be made based on the actual allowable costs incurred for the period involved. Condition – During our review of the Organization’s indirect cost rate calculation, we were unable to be provided with a true-up of actual indirect costs based on the final rates versus the provisional rates used by the Organization. Cause – The Organization did not have internal controls in place to ensure that the provisional rate utilized was in line with actual allowable costs incurred for the period involved. Effect or potential effect – Total indirect costs charged by the Organization may not be in line with the final rates determined by the oversight agency. Questioned costs – None Context – 3 out of 4 major programs tested did not have calculated indirect cost rates that agreed with their respective agreements. Identification as a repeat finding, if applicable – Is a repeat finding (2022-008) Recommendation – We recommend the Organization establish an internal control procedure to ensure that indirect costs charged to the federal program using the provisional rate are appropriately adjusted, if necessary, based on actual costs incurred. We recommend that on an annual basis, the Organization obtain an updated Nonprofit Rate Agreement from the federal government that shows final approved rates based on actual costs. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program _ Assistance Listing Number 10.557, Special Supplemental Nutrition Program for Women, Infants, and Children, Department of Agriculture; Assistance Listing Number 93.676, Unaccompanied Alien Children Program, Department of Health and Human Services; Assistance Listing Number 93.870, Maternal, Infant and Early Childhood Home Visiting Grant Program, Department of Health and Human Services Criteria or specific requirement – As stated in 2 CFR §200.303, the non-federal entity (i.e., the Organization) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.414 Subpart F, Appendix IV, Section C.2.f, the provisional and final rates must be negotiated where neither predetermined nor fixed rates are appropriate. Predetermined or fixed rates may replace provisional rates at any time prior to the close of the organization's fiscal year. If that event does not occur, a final rate will be established and upward or downward adjustments will be made based on the actual allowable costs incurred for the period involved. Condition – During our review of the Organization’s indirect cost rate calculation, we were unable to be provided with a true-up of actual indirect costs based on the final rates versus the provisional rates used by the Organization. Cause – The Organization did not have internal controls in place to ensure that the provisional rate utilized was in line with actual allowable costs incurred for the period involved. Effect or potential effect – Total indirect costs charged by the Organization may not be in line with the final rates determined by the oversight agency. Questioned costs – None Context – 3 out of 4 major programs tested did not have calculated indirect cost rates that agreed with their respective agreements. Identification as a repeat finding, if applicable – Is a repeat finding (2022-008) Recommendation – We recommend the Organization establish an internal control procedure to ensure that indirect costs charged to the federal program using the provisional rate are appropriately adjusted, if necessary, based on actual costs incurred. We recommend that on an annual basis, the Organization obtain an updated Nonprofit Rate Agreement from the federal government that shows final approved rates based on actual costs. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program _ Assistance Listing Number 93.224/93.527; Health Center Program Cluster; Department of Health and Human Services Criteria or specific requirement – Activities Allowed/Unallowed and Cost Principles; As stated in 2 CFR §200.303, the non-federal entity (i.e., the Organization) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition – The Organization was unable to provide evidence of approval for 8 expenditures charged to the federal program. Cause – The Organization did not consistently follow the internal control policies and procedures that it has in place to ensure each expenditure was properly approved. Effect or potential effect – There is a risk of misappropriation or charging unallowable expenditures to the program, resulting in actual and/or potential questioned costs. Questioned costs – None Context – Out of a population of 483 direct costs, a sample of 25 expenditures were selected for testing, and 8 did not have evidence of approval. The sample was not statistically valid. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – We recommend an individual with knowledge of the federal program review expenditures charged to the federal program and ensure all transactions are supported by documentation evidencing the nature and business purpose of each expenditure. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program _ Assistance Listing Number 93.224/93.527; Health Center Program Cluster; Department of Health and Human Services Criteria or specific requirement – Activities Allowed/Unallowed and Cost Principles; As stated in 2 CFR §200.303, the non-federal entity (i.e., the Organization) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition – The Organization was unable to provide evidence of approval for 8 expenditures charged to the federal program. Cause – The Organization did not consistently follow the internal control policies and procedures that it has in place to ensure each expenditure was properly approved. Effect or potential effect – There is a risk of misappropriation or charging unallowable expenditures to the program, resulting in actual and/or potential questioned costs. Questioned costs – None Context – Out of a population of 483 direct costs, a sample of 25 expenditures were selected for testing, and 8 did not have evidence of approval. The sample was not statistically valid. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – We recommend an individual with knowledge of the federal program review expenditures charged to the federal program and ensure all transactions are supported by documentation evidencing the nature and business purpose of each expenditure. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program _ Assistance Listing Number 93.224/93.527; Health Center Program Cluster; Department of Health and Human Services Criteria or specific requirement – Activities Allowed/Unallowed and Cost Principles; As stated in 2 CFR §200.303, the non-federal entity (i.e., the Organization) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition – The Organization was unable to provide evidence of approval for 8 expenditures charged to the federal program. Cause – The Organization did not consistently follow the internal control policies and procedures that it has in place to ensure each expenditure was properly approved. Effect or potential effect – There is a risk of misappropriation or charging unallowable expenditures to the program, resulting in actual and/or potential questioned costs. Questioned costs – None Context – Out of a population of 483 direct costs, a sample of 25 expenditures were selected for testing, and 8 did not have evidence of approval. The sample was not statistically valid. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – We recommend an individual with knowledge of the federal program review expenditures charged to the federal program and ensure all transactions are supported by documentation evidencing the nature and business purpose of each expenditure. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program _ Assistance Listing Number 93.224/93.527; Health Center Program Cluster; Department of Health and Human Services Criteria or specific requirement – Activities Allowed/Unallowed and Cost Principles; As stated in 2 CFR §200.303, the non-federal entity (i.e., the Organization) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition – The Organization was unable to provide evidence of approval for 8 expenditures charged to the federal program. Cause – The Organization did not consistently follow the internal control policies and procedures that it has in place to ensure each expenditure was properly approved. Effect or potential effect – There is a risk of misappropriation or charging unallowable expenditures to the program, resulting in actual and/or potential questioned costs. Questioned costs – None Context – Out of a population of 483 direct costs, a sample of 25 expenditures were selected for testing, and 8 did not have evidence of approval. The sample was not statistically valid. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – We recommend an individual with knowledge of the federal program review expenditures charged to the federal program and ensure all transactions are supported by documentation evidencing the nature and business purpose of each expenditure. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program _ Assistance Listing Number 93.224/93.527; Health Center Program Cluster; Department of Health and Human Services Criteria or specific requirement – Activities Allowed/Unallowed and Cost Principles; As stated in 2 CFR §200.303, the non-federal entity (i.e., the Organization) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition – The Organization was unable to provide evidence of approval for 8 expenditures charged to the federal program. Cause – The Organization did not consistently follow the internal control policies and procedures that it has in place to ensure each expenditure was properly approved. Effect or potential effect – There is a risk of misappropriation or charging unallowable expenditures to the program, resulting in actual and/or potential questioned costs. Questioned costs – None Context – Out of a population of 483 direct costs, a sample of 25 expenditures were selected for testing, and 8 did not have evidence of approval. The sample was not statistically valid. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – We recommend an individual with knowledge of the federal program review expenditures charged to the federal program and ensure all transactions are supported by documentation evidencing the nature and business purpose of each expenditure. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program – All federal programs Criteria or specific requirement – As stated in 2 CFR §200.303, the non-federal entity (i.e., the Center) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.214, the non-federal entity is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – During the 2022 audit, the predecessor auditor noted several cases in which the Organization did not perform, or did not maintain proper support to demonstrate that it performed checks via SAM.gov to ensure that potential vendors, contractors, or consultants are suspended or debarred. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. The matter has not been resolved in 2023. Cause – Management did not have effective internal controls in place to ensure that suspension and debarment was being performed prior to entering into contracts with vendors or contractors/consultants. Effect or potential effect – The Organization is exposed to an increased risk that future noncompliance could occur by entering into transactions with vendors, contractors, or consultants that are suspended and debarred. Questioned costs – None Context – The Organization failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a repeat finding, if applicable – Is a repeat finding (2022-010) Recommendation – We recommend the Organization implement internal controls to ensure that all vendors, contractors, and consultants are screened for suspension and debarment prior to entering into any executed contract. We further recommend that a policy be formalized and implemented that requires an annual screening of any current vendors, contractors, or consultants as well. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program – All federal programs Criteria or specific requirement – As stated in 2 CFR §200.303, the non-federal entity (i.e., the Center) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.214, the non-federal entity is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – During the 2022 audit, the predecessor auditor noted several cases in which the Organization did not perform, or did not maintain proper support to demonstrate that it performed checks via SAM.gov to ensure that potential vendors, contractors, or consultants are suspended or debarred. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. The matter has not been resolved in 2023. Cause – Management did not have effective internal controls in place to ensure that suspension and debarment was being performed prior to entering into contracts with vendors or contractors/consultants. Effect or potential effect – The Organization is exposed to an increased risk that future noncompliance could occur by entering into transactions with vendors, contractors, or consultants that are suspended and debarred. Questioned costs – None Context – The Organization failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a repeat finding, if applicable – Is a repeat finding (2022-010) Recommendation – We recommend the Organization implement internal controls to ensure that all vendors, contractors, and consultants are screened for suspension and debarment prior to entering into any executed contract. We further recommend that a policy be formalized and implemented that requires an annual screening of any current vendors, contractors, or consultants as well. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program – All federal programs Criteria or specific requirement – As stated in 2 CFR §200.303, the non-federal entity (i.e., the Center) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.214, the non-federal entity is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – During the 2022 audit, the predecessor auditor noted several cases in which the Organization did not perform, or did not maintain proper support to demonstrate that it performed checks via SAM.gov to ensure that potential vendors, contractors, or consultants are suspended or debarred. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. The matter has not been resolved in 2023. Cause – Management did not have effective internal controls in place to ensure that suspension and debarment was being performed prior to entering into contracts with vendors or contractors/consultants. Effect or potential effect – The Organization is exposed to an increased risk that future noncompliance could occur by entering into transactions with vendors, contractors, or consultants that are suspended and debarred. Questioned costs – None Context – The Organization failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a repeat finding, if applicable – Is a repeat finding (2022-010) Recommendation – We recommend the Organization implement internal controls to ensure that all vendors, contractors, and consultants are screened for suspension and debarment prior to entering into any executed contract. We further recommend that a policy be formalized and implemented that requires an annual screening of any current vendors, contractors, or consultants as well. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program – All federal programs Criteria or specific requirement – As stated in 2 CFR §200.303, the non-federal entity (i.e., the Center) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.214, the non-federal entity is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – During the 2022 audit, the predecessor auditor noted several cases in which the Organization did not perform, or did not maintain proper support to demonstrate that it performed checks via SAM.gov to ensure that potential vendors, contractors, or consultants are suspended or debarred. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. The matter has not been resolved in 2023. Cause – Management did not have effective internal controls in place to ensure that suspension and debarment was being performed prior to entering into contracts with vendors or contractors/consultants. Effect or potential effect – The Organization is exposed to an increased risk that future noncompliance could occur by entering into transactions with vendors, contractors, or consultants that are suspended and debarred. Questioned costs – None Context – The Organization failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a repeat finding, if applicable – Is a repeat finding (2022-010) Recommendation – We recommend the Organization implement internal controls to ensure that all vendors, contractors, and consultants are screened for suspension and debarment prior to entering into any executed contract. We further recommend that a policy be formalized and implemented that requires an annual screening of any current vendors, contractors, or consultants as well. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program – All federal programs Criteria or specific requirement – As stated in 2 CFR §200.303, the non-federal entity (i.e., the Center) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.214, the non-federal entity is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – During the 2022 audit, the predecessor auditor noted several cases in which the Organization did not perform, or did not maintain proper support to demonstrate that it performed checks via SAM.gov to ensure that potential vendors, contractors, or consultants are suspended or debarred. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. The matter has not been resolved in 2023. Cause – Management did not have effective internal controls in place to ensure that suspension and debarment was being performed prior to entering into contracts with vendors or contractors/consultants. Effect or potential effect – The Organization is exposed to an increased risk that future noncompliance could occur by entering into transactions with vendors, contractors, or consultants that are suspended and debarred. Questioned costs – None Context – The Organization failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a repeat finding, if applicable – Is a repeat finding (2022-010) Recommendation – We recommend the Organization implement internal controls to ensure that all vendors, contractors, and consultants are screened for suspension and debarment prior to entering into any executed contract. We further recommend that a policy be formalized and implemented that requires an annual screening of any current vendors, contractors, or consultants as well. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program – All federal programs Criteria or specific requirement – As stated in 2 CFR §200.303, the non-federal entity (i.e., the Center) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.214, the non-federal entity is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – During the 2022 audit, the predecessor auditor noted several cases in which the Organization did not perform, or did not maintain proper support to demonstrate that it performed checks via SAM.gov to ensure that potential vendors, contractors, or consultants are suspended or debarred. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. The matter has not been resolved in 2023. Cause – Management did not have effective internal controls in place to ensure that suspension and debarment was being performed prior to entering into contracts with vendors or contractors/consultants. Effect or potential effect – The Organization is exposed to an increased risk that future noncompliance could occur by entering into transactions with vendors, contractors, or consultants that are suspended and debarred. Questioned costs – None Context – The Organization failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a repeat finding, if applicable – Is a repeat finding (2022-010) Recommendation – We recommend the Organization implement internal controls to ensure that all vendors, contractors, and consultants are screened for suspension and debarment prior to entering into any executed contract. We further recommend that a policy be formalized and implemented that requires an annual screening of any current vendors, contractors, or consultants as well. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program – All federal programs Criteria or specific requirement – As stated in 2 CFR §200.303, the non-federal entity (i.e., the Center) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.214, the non-federal entity is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – During the 2022 audit, the predecessor auditor noted several cases in which the Organization did not perform, or did not maintain proper support to demonstrate that it performed checks via SAM.gov to ensure that potential vendors, contractors, or consultants are suspended or debarred. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. The matter has not been resolved in 2023. Cause – Management did not have effective internal controls in place to ensure that suspension and debarment was being performed prior to entering into contracts with vendors or contractors/consultants. Effect or potential effect – The Organization is exposed to an increased risk that future noncompliance could occur by entering into transactions with vendors, contractors, or consultants that are suspended and debarred. Questioned costs – None Context – The Organization failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a repeat finding, if applicable – Is a repeat finding (2022-010) Recommendation – We recommend the Organization implement internal controls to ensure that all vendors, contractors, and consultants are screened for suspension and debarment prior to entering into any executed contract. We further recommend that a policy be formalized and implemented that requires an annual screening of any current vendors, contractors, or consultants as well. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program – All federal programs Criteria or specific requirement – As stated in 2 CFR §200.303, the non-federal entity (i.e., the Center) 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 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 in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.214, the non-federal entity is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – During the 2022 audit, the predecessor auditor noted several cases in which the Organization did not perform, or did not maintain proper support to demonstrate that it performed checks via SAM.gov to ensure that potential vendors, contractors, or consultants are suspended or debarred. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. The matter has not been resolved in 2023. Cause – Management did not have effective internal controls in place to ensure that suspension and debarment was being performed prior to entering into contracts with vendors or contractors/consultants. Effect or potential effect – The Organization is exposed to an increased risk that future noncompliance could occur by entering into transactions with vendors, contractors, or consultants that are suspended and debarred. Questioned costs – None Context – The Organization failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a repeat finding, if applicable – Is a repeat finding (2022-010) Recommendation – We recommend the Organization implement internal controls to ensure that all vendors, contractors, and consultants are screened for suspension and debarment prior to entering into any executed contract. We further recommend that a policy be formalized and implemented that requires an annual screening of any current vendors, contractors, or consultants as well. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program – All federal programs Criteria or specific requirement – According to 2 CFR §200.303, 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). Additionally, according to 2 CFR §200.318 Procurement standards, 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. Title 2, Subtitle A Chapter II Part 200 Subpart D 200.319 Procurement Standards. All procurement transactions for the acquisition of property or services required under a federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and §200.320. The non-federal entity must have written procedures for procurement transactions. These procedures must ensure that all solicitations: (1) Incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured. Such description must not, in competitive procurements, contain features which unduly restrict competition. The description may include a statement of the qualitative nature of the material, product or service to be procured and, when necessary, must set forth those minimum essential characteristics and standards to which it must conform if it is to satisfy its intended use. Noncompetitive procurements can only be awarded in accordance with §200.320(c). According to 2 CFR §200.320 Procurement Standards, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: 1. The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); 2. The item is available only from a single source; 3. The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; 4. The federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-federal entity; or 5. After solicitation of a number of sources, competition is determined inadequate. Condition – During the 2022 audit, the predecessor auditor determined that the Organization did not clearly document the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, for noncompetitive procurements, there was no documentation to support which of the five criteria was met to allow for the noncompetitive procurement. The matter has not been resolved in 2023. Cause – Management did not have effective internal controls in place to ensure that procurement requirements were adequately documented and retained. Effect or potential effect – Procurement records were insufficient to meet the requirements noted in the Criteria section above, as well as the Organization's internal procurement policy. Questioned costs – None Context – The predecessor auditor noted that several items selected for testing did not document the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, the predecessor auditor noted that several items selected for testing for noncompetitive procurements did not maintain documentation of which of the five criteria were met to allow for the noncompetitive procurement. Identification as a repeat finding, if applicable – Is a repeat finding (2022-007) Recommendation – We recommend the Organization retain sufficient procurement documentation to meet the requirements noted in the Criteria section above. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.
Information on the federal program – All federal programs Criteria or specific requirement – According to 2 CFR §200.303, 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). Additionally, according to 2 CFR §200.318 Procurement standards, 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. Title 2, Subtitle A Chapter II Part 200 Subpart D 200.319 Procurement Standards. All procurement transactions for the acquisition of property or services required under a federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and §200.320. The non-federal entity must have written procedures for procurement transactions. These procedures must ensure that all solicitations: (1) Incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured. Such description must not, in competitive procurements, contain features which unduly restrict competition. The description may include a statement of the qualitative nature of the material, product or service to be procured and, when necessary, must set forth those minimum essential characteristics and standards to which it must conform if it is to satisfy its intended use. Noncompetitive procurements can only be awarded in accordance with §200.320(c). According to 2 CFR §200.320 Procurement Standards, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: 1. The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); 2. The item is available only from a single source; 3. The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; 4. The federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-federal entity; or 5. After solicitation of a number of sources, competition is determined inadequate. Condition – During the 2022 audit, the predecessor auditor determined that the Organization did not clearly document the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, for noncompetitive procurements, there was no documentation to support which of the five criteria was met to allow for the noncompetitive procurement. The matter has not been resolved in 2023. Cause – Management did not have effective internal controls in place to ensure that procurement requirements were adequately documented and retained. Effect or potential effect – Procurement records were insufficient to meet the requirements noted in the Criteria section above, as well as the Organization's internal procurement policy. Questioned costs – None Context – The predecessor auditor noted that several items selected for testing did not document the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, the predecessor auditor noted that several items selected for testing for noncompetitive procurements did not maintain documentation of which of the five criteria were met to allow for the noncompetitive procurement. Identification as a repeat finding, if applicable – Is a repeat finding (2022-007) Recommendation – We recommend the Organization retain sufficient procurement documentation to meet the requirements noted in the Criteria section above. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.