Significant Deficiency in Internal Control over Federal Programs Lack of Fiscal Policies and Procedures in Accordance with the Uniform Guidance Assistance Listing Number: 93.328 Name of Federal Program or Cluster: Epidemiology and Laboratory Capacity for Infectious Diseases Name of Federal Agency: Department of Health and Human Services Name of Pass-Through Entities: State of Wisconsin Department of Health Services The Code of Federal Regulations (CFR) Section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. 2 CFR§200.302(b)(6-7) Financial Management: - Written procedures are required to implement the requirements of §200.305. - Written procedures are required for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the Federal award.WHCA’s written policies and procedures lack some of the requirements required by the Code of Federal Regulations. There is an increased risk that the Association could potentially charge unallowable costs to federal awards or be noncompliant with other areas of the Code of Federal Regulations. We recommend the Association create formal written fiscal policies and procedures that conform to the uniform guidance. No Staff at the WHCA are dedicated to adhering to the regulations. The Executive Director, Vice President of Workforce Development, and the Director of Administration & Association completed a certification course on Federal allowable costs. In managing the federal awards, staff references this knowledge to guide the spending of the award.
2023-001 Eligibility – Source Documentation Prior Year Finding Number: 2022-002 Year of Finding Origination: 2022 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Housing and Urban Development Program: 14.871 Section 8 Housing Choice Vouchers 14.879 Mainstream Vouchers Award Number and Year: Assistance Listing Number Award Number Year 14.871 MN163VO/MN163AF 2023 14.871 MN163EP/MN163EI/MN163ES/MN163EF/MN163EH 2023 14.871 MPHA 22.059 2023 14.879 MN163DV/MN163F 2023 Pass-Through Agency: N/A – Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Per Title 24 U.S. Code of Federal Regulations § 982.553(a)(2), each member over the age of 18 is subject to a criminal background check prior to admission into the program. In addition, Public Housing Authorities are required by Notice PIH 2010-19 to provide the “Debts Owed to Public Housing Agencies and Terminations” notice to all applicants and program participants over the age of 18, and all such individuals are required to acknowledge receipt of the notice by signature located on the notice itself. Condition: A sample of 40 case files was reviewed, and the following issues were identified: • three case files were missing documentation or evidence that a criminal background check was performed for one or more adult members of the household. • one case file was missing the "Debts Owed" form for one adult member of the household. Questioned Costs: None. Context: HousingPro is the system used by the Metropolitan Council Housing Redevelopment Authority to calculate the monthly Housing Assistance Payments for the Housing Choice Voucher program participants and to document and support eligibility determinations. Proper input of information into the system and documentation retention are important functions to ensure accurate and proper eligibility determination and calculations of Housing Assistance Payments. The deviations identified did not impact eligibility or result in an incorrect level of benefit amount. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Errors in eligibility-determining factors increase the risk that program participants will receive benefits when they are not eligible or are paid at an incorrect benefit amount. Cause: Personnel entering case information into HousingPro did not ensure necessary documentation was completed and/or maintained. Recommendation: We recommend that the Metropolitan Council implement additional procedures to provide reasonable assurance that all necessary documentation is maintained supporting compliance with federal regulations. View of Responsible Official: Concur.
2023-001 Eligibility – Source Documentation Prior Year Finding Number: 2022-002 Year of Finding Origination: 2022 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Housing and Urban Development Program: 14.871 Section 8 Housing Choice Vouchers 14.879 Mainstream Vouchers Award Number and Year: Assistance Listing Number Award Number Year 14.871 MN163VO/MN163AF 2023 14.871 MN163EP/MN163EI/MN163ES/MN163EF/MN163EH 2023 14.871 MPHA 22.059 2023 14.879 MN163DV/MN163F 2023 Pass-Through Agency: N/A – Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Per Title 24 U.S. Code of Federal Regulations § 982.553(a)(2), each member over the age of 18 is subject to a criminal background check prior to admission into the program. In addition, Public Housing Authorities are required by Notice PIH 2010-19 to provide the “Debts Owed to Public Housing Agencies and Terminations” notice to all applicants and program participants over the age of 18, and all such individuals are required to acknowledge receipt of the notice by signature located on the notice itself. Condition: A sample of 40 case files was reviewed, and the following issues were identified: • three case files were missing documentation or evidence that a criminal background check was performed for one or more adult members of the household. • one case file was missing the "Debts Owed" form for one adult member of the household. Questioned Costs: None. Context: HousingPro is the system used by the Metropolitan Council Housing Redevelopment Authority to calculate the monthly Housing Assistance Payments for the Housing Choice Voucher program participants and to document and support eligibility determinations. Proper input of information into the system and documentation retention are important functions to ensure accurate and proper eligibility determination and calculations of Housing Assistance Payments. The deviations identified did not impact eligibility or result in an incorrect level of benefit amount. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Errors in eligibility-determining factors increase the risk that program participants will receive benefits when they are not eligible or are paid at an incorrect benefit amount. Cause: Personnel entering case information into HousingPro did not ensure necessary documentation was completed and/or maintained. Recommendation: We recommend that the Metropolitan Council implement additional procedures to provide reasonable assurance that all necessary documentation is maintained supporting compliance with federal regulations. View of Responsible Official: Concur.
2023-001 Eligibility – Source Documentation Prior Year Finding Number: 2022-002 Year of Finding Origination: 2022 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Housing and Urban Development Program: 14.871 Section 8 Housing Choice Vouchers 14.879 Mainstream Vouchers Award Number and Year: Assistance Listing Number Award Number Year 14.871 MN163VO/MN163AF 2023 14.871 MN163EP/MN163EI/MN163ES/MN163EF/MN163EH 2023 14.871 MPHA 22.059 2023 14.879 MN163DV/MN163F 2023 Pass-Through Agency: N/A – Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Per Title 24 U.S. Code of Federal Regulations § 982.553(a)(2), each member over the age of 18 is subject to a criminal background check prior to admission into the program. In addition, Public Housing Authorities are required by Notice PIH 2010-19 to provide the “Debts Owed to Public Housing Agencies and Terminations” notice to all applicants and program participants over the age of 18, and all such individuals are required to acknowledge receipt of the notice by signature located on the notice itself. Condition: A sample of 40 case files was reviewed, and the following issues were identified: • three case files were missing documentation or evidence that a criminal background check was performed for one or more adult members of the household. • one case file was missing the "Debts Owed" form for one adult member of the household. Questioned Costs: None. Context: HousingPro is the system used by the Metropolitan Council Housing Redevelopment Authority to calculate the monthly Housing Assistance Payments for the Housing Choice Voucher program participants and to document and support eligibility determinations. Proper input of information into the system and documentation retention are important functions to ensure accurate and proper eligibility determination and calculations of Housing Assistance Payments. The deviations identified did not impact eligibility or result in an incorrect level of benefit amount. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Errors in eligibility-determining factors increase the risk that program participants will receive benefits when they are not eligible or are paid at an incorrect benefit amount. Cause: Personnel entering case information into HousingPro did not ensure necessary documentation was completed and/or maintained. Recommendation: We recommend that the Metropolitan Council implement additional procedures to provide reasonable assurance that all necessary documentation is maintained supporting compliance with federal regulations. View of Responsible Official: Concur.
2023-001 Eligibility – Source Documentation Prior Year Finding Number: 2022-002 Year of Finding Origination: 2022 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Housing and Urban Development Program: 14.871 Section 8 Housing Choice Vouchers 14.879 Mainstream Vouchers Award Number and Year: Assistance Listing Number Award Number Year 14.871 MN163VO/MN163AF 2023 14.871 MN163EP/MN163EI/MN163ES/MN163EF/MN163EH 2023 14.871 MPHA 22.059 2023 14.879 MN163DV/MN163F 2023 Pass-Through Agency: N/A – Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Per Title 24 U.S. Code of Federal Regulations § 982.553(a)(2), each member over the age of 18 is subject to a criminal background check prior to admission into the program. In addition, Public Housing Authorities are required by Notice PIH 2010-19 to provide the “Debts Owed to Public Housing Agencies and Terminations” notice to all applicants and program participants over the age of 18, and all such individuals are required to acknowledge receipt of the notice by signature located on the notice itself. Condition: A sample of 40 case files was reviewed, and the following issues were identified: • three case files were missing documentation or evidence that a criminal background check was performed for one or more adult members of the household. • one case file was missing the "Debts Owed" form for one adult member of the household. Questioned Costs: None. Context: HousingPro is the system used by the Metropolitan Council Housing Redevelopment Authority to calculate the monthly Housing Assistance Payments for the Housing Choice Voucher program participants and to document and support eligibility determinations. Proper input of information into the system and documentation retention are important functions to ensure accurate and proper eligibility determination and calculations of Housing Assistance Payments. The deviations identified did not impact eligibility or result in an incorrect level of benefit amount. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Errors in eligibility-determining factors increase the risk that program participants will receive benefits when they are not eligible or are paid at an incorrect benefit amount. Cause: Personnel entering case information into HousingPro did not ensure necessary documentation was completed and/or maintained. Recommendation: We recommend that the Metropolitan Council implement additional procedures to provide reasonable assurance that all necessary documentation is maintained supporting compliance with federal regulations. View of Responsible Official: Concur.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements, which must include the total Federal awards expended. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements, which must include the total Federal awards expended. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements, which must include the total Federal awards expended. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements, which must include the total Federal awards expended. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements, which must include the total Federal awards expended. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements, which must include the total Federal awards expended. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements, which must include the total Federal awards expended. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001—Late Reporting Submission Repeat Finding: No Federal Program Title—U.S. Department of Labor Registered Apprenticeship 17.285 Condition and Context The Foundation did not submit quarterly reports within the required time frame (four out of four quarterly reports tested). The first quarterly report covered the period from January 1 through March 31, 2023, and was due on May 15, 2023; the Foundation submitted the report on May 16, 2023. The second quarterly report covered the period from April 1 through June 30, 2023 and was due on August 14, 2023; the Foundation submitted the report on August 15, 2023. The third quarterly report covered the period from July 1 through September 30, 2023, and was due on November 14, 2023; the Foundation submitted the report on November 16, 2023. The fourth quarterly report covered the period from October 1 through December 31, 2023, and was due on February 14, 2024; the Foundation submitted the report on February 15, 2024. Criteria The Department of Labor requires the ETA-9130 report to be submitted on a quarterly basis by specific dates. 2 CFR Section 200.303 requires entities receiving federal awards to establish and maintain internal controls deigned to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure the timely and accurate posting of reports. Questioned Costs There were no questioned costs with respect to this finding. Cause The Foundation did not have effective controls in place to ensure reports were submitted timely. Reports were reviewed prior to submission but were not timely submitted. Effect The untimely submission of reports is not compliant with the requirements of the grant award and could impact future funding. Recommendation We recommend the Foundation implement controls to ensure required reports are submitted timely. Views of Responsible Officials We agree with this finding. See corrective action plan.
FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY 2023 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. INDIANA STATE BOARD OF ACCOUNTS 17 MIAMI COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The County elected to receive the standard revenue loss allowance, allowing them to claim its total State and Local Fiscal Recovery Funds (SLFRF) allocation of $6,898,567 as revenue loss to use for government services. As such, all SLFRF program funds to date were expended under the revenue loss eligible use category. The U.S. Department of the Treasury (Treasury) determined that there are no subawards under this eligible use category, and that recipients' use of revenue loss funds would not give rise to subrecipient relationships as there is no federal program or purpose to carry out in the case of the revenue loss portion of the award. Prior to entering into subawards and covered transactions with SLFRF award funds, recipients are required to verify that such contracts and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under procurement and non-procurement transactions (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Due to the Treasury's determination that the revenue loss eligible use category does not give rise to subawards, the County was only required to comply with suspension and debarment requirements, related to covered transactions. Upon inquiry of the County to determine its policies and procedures related to suspension and debarment requirements, the County stated that they did not have policies or procedures in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. Ten covered transactions to six different vendors for goods or services that equaled or exceeded $25,000 that were paid from SLFRF funds were identified. Each transaction was examined to determine whether the County verified the suspension and debarment status of the vendor prior to payment. The County had not verified the vendor's suspension and debarment status for any of the ten covered transactions listed below prior to issuing payment. Covered Transactions Tested Description Amount Tractors and Equipment for Highway Department (1 transaction, 1 vendor) $ 155,610 Various local contractors for excavating services (7 transactions, 3 vendors) 291,425 Services on the HVAC for the Courthouse (1 transaction, 1 vendor) 75,000 Purchase of culverts (1 transaction, 1 vendor) 29,933 The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 18 MIAMI COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause The County had not implemented an effectively designed system of internal controls for suspension and debarment. The County did not verify any covered transactions identified in testing that they were not suspended or debarred prior to entering into the covered transaction. Effect Without the proper implementation of an effectively designed system of internal controls, the County cannot ensure the vendors paid with federal funds are eligible to participate in federal programs. Any program funds the County used to pay vendors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions or the federal award could result in the loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the County strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any covered transactions. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY 2023 Compliance Requirement: Reporting Audit Finding: Material Weakness Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-004. Condition and Context Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon type of recipient and its population, as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. The County was classified as a county with a population below 250,000 residents that received an allocation of less than $10 million in State and Local Fiscal Recovery Funds. As such, the P&E report, covering the period from April 1, 2022 to March 31, 2023, was required to be submitted to the Treasury by April 30, 2023. The County submitted the P&E report by April 30, 2023, as required; however, there were no internal controls in place that would likely be effective in preventing, or detecting and correcting, noncompliance related to the P&E report. The County Auditor prepared and submitted the report without an oversight or review process. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause The County did not implement an effectively designed system of internal controls over reporting. There was no indication of internal controls in place over reporting. INDIANA STATE BOARD OF ACCOUNTS 20 MIAMI COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls over reporting, the County cannot ensure that the reports submitted are materially accurate and correct. If there was a proper implementation of an effectively designed system of internal controls over reporting, the County would have been able to detect any errors prior to submission. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County design and implement a proper system of internal controls, including policies and procedures to ensure that the County provides the Treasury with complete and accurate information for the P&E report. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Department of Treasury Pass-through County of Warren, Kentucky; Coronavirus State and Local Fiscal Recovery Funds (LSFRF) - Assistance Listing No. 21.027; Grant period - Year ended December 31, 2023 Criteria and Condition: 2 CFR 200.303 requires the non-federal entity to establish and maintain effective internal controls over compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Non-federal entities are prohibited from contract with our making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. The District's processes over procurement, suspension, and debarment could be enhanced as costs were charged to the Coronavirus State and Local Fiscal Recovery Funds grant that were paid to vendors that had not been checked for suspension or debarment. Cause: Certain internal controls were not in place to properly detect if vendors had been suspended or debarred. Effect: The cost of the assistance may be disallowed. Questioned Costs: N/A Context: Two vendors were tested that were awared contracts for goods or services and charged to the Coronavirus State and Local Fiscal Recovery Funds grant. The test found the vendors had not been checked for suspension or debarment. Recommendation: The District should enhance the review of vendors for suspension or debarment. Views of Responsible Officials and Planned Correct Actions: The District concurs with the finding, see corrective action plan
Department of Treasury Pass-through County of Warren, Kentucky; Coronavirus State and Local Fiscal Recovery Funds (LSFRF) - Assistance Listing No. 21.027; Grant period - Year ended December 31, 2023 Criteria and Condition: 2 CFR 200.303 requires the non-federal entity to establish and maintaineffective internal controsl over compliance with Federal staues, regulations, and the terms and conditions of the Federal award including proper tracking of grant expenditures for compliance. 31 CFR Part 35.5(a) defines the period of performance for the Coronavirus State and Local Fiscal Recovery Funds grant as beginning on March 3, 2021. The District's processes over approving allwoable costs in the proper period of performance could be enhanced as costs were charged to the Coronavirus State and Local Fiscal Recovery Funds grant that fell outside of the proper period of performance. Cause: Certain internal controls were not in place to prevent costs from outside of the proper period of performance from being charged to the grant. Effect: The cost of the assistance may be disallowed. Questioned Costs: $3,670 Context: Transactions prior to March 3, 2021 were identified in test work. The full amount of these costs charged to the program was determined to be $3,670. Recommendation: The District should enhance the review of costs prior to being transferred or charged to the grant to ensure it includes a review for proper period of performance. Viewes of Responsible Officials and Planned Corrective Actions: The District concurs with the finding, see corrective action plan
Finding 2023-001 Identification of the federal program: Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF) Pass-Through Grantor: Not applicable Pass-Through Award Number: Not applicable Pass-Through Award Period: 1/1/2020–12/31/2023 (Periods 5 and 6) Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” The Provider Relief Programs: Provider Relief Fund and ARP Rural Payments Frequently Asked Questions states the following: “If a Reporting Entity has more lost revenues for a “Payment Received Period” than it received Provider Relief Fund and/or ARP Rural payments for the same period, can those lost revenues be carried forward and applied against payments received during later “Payment Received Periods” and included in the lost revenues reported during later reporting periods? (Modified 5/5/2023). Yes. Provider Relief Fund and/or ARP Rural payments may be applied to expenses and lost revenues according to the period of availability of funding. However, expenses and lost revenues may not be duplicated. Specifically, payments received may not be applied to the same expenses and lost revenues that Provider Relief Fund or ARP Rural payments received in prior payment periods already reimbursed. The Payment Received Periods described in the Post-Payment Notice of Reporting Requirements determine the period of availability of funding and when reports are due. The opportunity to apply Provider Relief Fund payments (excluding the Nursing Home Infection Control Distribution) and ARP Rural payments for lost revenues will be available up to June 30, 2023, the end of the quarter in which the COVID-19 Public Health Emergency ends.” Condition: The “Total Lost Revenues for the Period of Availability (January 1, 2020 to June 30, 2023)” line in the HRSA PRF portal for Spectrum Health System (the Parent), TIN 383382353, General Distribution HRSA PRF report in Reporting Period 5 was $108,697,843. The amount of lost revenues reported for Period 5 should have been $107,045,743. The difference represents a $1.6 million error as a result of improperly adjusting for targeted funds to determine the Parent’s lost revenues for period 5. Cause: Management’s internal controls over the review of input of lost revenues into the HRSA PRF portal were not sufficient to ensure the lost revenues recorded in the General Distribution portal “Total Lost Revenues for the Period of Availability (January 1, 2020 to June 30, 2023)” line were appropriate. Effect or potential effect: The lost revenues reported in the HRSA PRF portal were misstated. Questioned costs: None. Context: There were three HRSA PRF reports submitted for the year ended December 31, 2023. We tested all three reports. Per our inspection of our sample of the three Corewell Health West HRSA PRF portal submissions for reporting period 5, we identified in one report that the “Total Lost Revenues for the Period of Availability (January 1, 2020 to June 30, 2023) line” was overstated by $1.6 million. The total amount of lost revenue reported for Period 5 was $107,045,743. The System had sufficient lost revenues even with the reporting misstatement. Total expenses reported on the Schedule for PRF for the year ended December 31, 2023, are $7,678,128. Identification as a repeat finding, if applicable: Not a repeat finding. Recommendation: We recommend that if PRF funding were received in future periods, management should implement more robust internal controls for review of the lost revenue input into the HRSA PRF Portal. Views of responsible officials: No further lost revenue reporting is required on the HRSA PRF Portal. Management will implement more robust internal controls in preparation for similar future filings.
Finding Number: 2023-001 Internal Control over Compliance and Compliance with the Subrecipient Monitoring Compliance Requirement, Repeat Finding, Finding No. 2022-001 Identification of the Major Federal Program: Programs: Government Agency: Inclusion Across the Nation of Communities of Learners of Underrepresented Discoverers in Engineering and Science Assistance Listing Number: 47.076 Award Number: HRD-1834540 Award Years: 09/01/2018 – 02/28/2025 PhysTEC: Building a Solution to the National Physics Teacher Shortage Assistance Listing Number: 47.049 Award Number: PHY-1707990 Award Years: 07/01/2017 – 06/30/2023 National Science Foundation (NSF) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with the Uniform Guidance in 2 CFR Section 200.331, a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. reviewing financial and programmatic (performance and special reports) required by the PTE; 2. following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means; 3. issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Furthermore, under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). If a subaward/subcontract was subject to reporting under the Transparency Act, the action was required to be reported in FSRS no later than the last day of the month following the month in which the subaward/subcontract amendment obligation was made or in the subcontract award/subcontract modification was made. Conditions – Our examination of the program’s subrecipient monitoring requirements includes the review and approval of financial and performance quarterly reports by the program managers. The quarterly reports are prepared by APS’ grants administrator with inputs provided by the subrecipient submitted to the program managers. Of the program’s twenty (20) subrecipients, we examined eight (8) subrecipients and observed that although the respective program managers had monitoring oversight of the various grant’s financial and programmatic activities, there was no formal evidentiary documentation to support the monitoring oversight process performed by the program managers. Furthermore, our examination of the program’s subrecipient monitoring requirements includes follow-ups by APS to ensure the subrecipients take timely and appropriate action on all deficiencies pertaining to federal awards provided to the subrecipients which have been detected through reviews of audits, on-site reviews, and other means. We selected six (6) subrecipients for testing and noted that for two (2) samples selected APS was unable to provide evidence that it monitored the subrecipients through review of its single audit reports, on-site reviews, and other means. We also tested a sample of three (3) subrecipients and our examination of the monitoring and reporting requirements revealed that APS did not report the information on a subaward of $30,000 or more in federal funds timely and on one (1) of the sub awards reported, the contract award amount reported is less than the actual expenditures incurred by the subrecipient. APS began implementation of its corrective action plan on June 5, 2023, and the exceptions identified above is as a result of the fact that APS was still in the implementation process of its corrective action plan. Cause - Management does not have adequate internal controls and policies and procedures in place to ensure that a review is performed on the financial and programmatic reports in a timely manner and to ensure that its subrecipients do not have any audit deficiencies relating to federal award programs and if any deficiencies are detected, that the subrecipients takes timely and appropriate action to resolve the deficiencies identified. There is also a lack of established monitoring and internal control procedures in place to ensure that reports required under the Transparency Act are prepared and submitted timely in FSRS Reporting System resulted in APS’ noncompliance with the reporting requirements. Effect or potential effect – APS is not in compliance with the subrecipient monitoring requirements as it did not maintain consistent documented evidence of its monitoring of subrecipients. In addition, failure to comply with the reporting requirements of the Uniform Guidance could result in the awarding agency taking action such as reducing future funding. Questioned Costs – None. Context – These are conditions identified per review of APS compliance with specified compliance requirements using a statistically valid sample. Recommendations – BDO recommends that APS continue to apply the implemented policies, procedures and controls that will ensure that all requisite reports are reviewed, and evidence of review are documented and maintained. Furthermore, APS should continue to implement policies to obtain and review single audit reports of its subrecipients in order to ensure compliance with all the required laws, guidelines and requirement under the award. BDO recommends that APS continues to implement established policies and procedure over the preparation and timely submission of reports required under the Transparency Act to ensure compliance with reporting requirements. Views of Responsible Officials - APS concurs with this finding. APS’ corrective action is described in the Management’s Corrective Action Plan included below.
Finding Number: 2023-001 Internal Control over Compliance and Compliance with the Subrecipient Monitoring Compliance Requirement, Repeat Finding, Finding No. 2022-001 Identification of the Major Federal Program: Programs: Government Agency: Inclusion Across the Nation of Communities of Learners of Underrepresented Discoverers in Engineering and Science Assistance Listing Number: 47.076 Award Number: HRD-1834540 Award Years: 09/01/2018 – 02/28/2025 PhysTEC: Building a Solution to the National Physics Teacher Shortage Assistance Listing Number: 47.049 Award Number: PHY-1707990 Award Years: 07/01/2017 – 06/30/2023 National Science Foundation (NSF) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with the Uniform Guidance in 2 CFR Section 200.331, a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. reviewing financial and programmatic (performance and special reports) required by the PTE; 2. following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means; 3. issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Furthermore, under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). If a subaward/subcontract was subject to reporting under the Transparency Act, the action was required to be reported in FSRS no later than the last day of the month following the month in which the subaward/subcontract amendment obligation was made or in the subcontract award/subcontract modification was made. Conditions – Our examination of the program’s subrecipient monitoring requirements includes the review and approval of financial and performance quarterly reports by the program managers. The quarterly reports are prepared by APS’ grants administrator with inputs provided by the subrecipient submitted to the program managers. Of the program’s twenty (20) subrecipients, we examined eight (8) subrecipients and observed that although the respective program managers had monitoring oversight of the various grant’s financial and programmatic activities, there was no formal evidentiary documentation to support the monitoring oversight process performed by the program managers. Furthermore, our examination of the program’s subrecipient monitoring requirements includes follow-ups by APS to ensure the subrecipients take timely and appropriate action on all deficiencies pertaining to federal awards provided to the subrecipients which have been detected through reviews of audits, on-site reviews, and other means. We selected six (6) subrecipients for testing and noted that for two (2) samples selected APS was unable to provide evidence that it monitored the subrecipients through review of its single audit reports, on-site reviews, and other means. We also tested a sample of three (3) subrecipients and our examination of the monitoring and reporting requirements revealed that APS did not report the information on a subaward of $30,000 or more in federal funds timely and on one (1) of the sub awards reported, the contract award amount reported is less than the actual expenditures incurred by the subrecipient. APS began implementation of its corrective action plan on June 5, 2023, and the exceptions identified above is as a result of the fact that APS was still in the implementation process of its corrective action plan. Cause - Management does not have adequate internal controls and policies and procedures in place to ensure that a review is performed on the financial and programmatic reports in a timely manner and to ensure that its subrecipients do not have any audit deficiencies relating to federal award programs and if any deficiencies are detected, that the subrecipients takes timely and appropriate action to resolve the deficiencies identified. There is also a lack of established monitoring and internal control procedures in place to ensure that reports required under the Transparency Act are prepared and submitted timely in FSRS Reporting System resulted in APS’ noncompliance with the reporting requirements. Effect or potential effect – APS is not in compliance with the subrecipient monitoring requirements as it did not maintain consistent documented evidence of its monitoring of subrecipients. In addition, failure to comply with the reporting requirements of the Uniform Guidance could result in the awarding agency taking action such as reducing future funding. Questioned Costs – None. Context – These are conditions identified per review of APS compliance with specified compliance requirements using a statistically valid sample. Recommendations – BDO recommends that APS continue to apply the implemented policies, procedures and controls that will ensure that all requisite reports are reviewed, and evidence of review are documented and maintained. Furthermore, APS should continue to implement policies to obtain and review single audit reports of its subrecipients in order to ensure compliance with all the required laws, guidelines and requirement under the award. BDO recommends that APS continues to implement established policies and procedure over the preparation and timely submission of reports required under the Transparency Act to ensure compliance with reporting requirements. Views of Responsible Officials - APS concurs with this finding. APS’ corrective action is described in the Management’s Corrective Action Plan included below.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
A material weakness relating to the Organization's compliance with the Uniform Guidance are reported in the Independent Auditor's Report on Compliance for Each Major Federal Program and Reporting on Internal Control over Compliance Required by the Department of Health Services Audit Guide. Finding 2023-001 is reported as a material weakness. Material Weakness in Internal Controls over Compliance. Condition: Management did not implement internal controls over reporting and review of allowable costs. It was noted while testing key controls over Arbor Place's financial records. Criteria: Arbor Place must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in Arbor Place’s internal controls. Cause: Management did not design and implement internal controls to review financial records.
Department of Agriculture Federal Assistance Listing #10.766 Community Facilities Loans and Grants Cluster Special Tests and Provisions Material Weakness in Internal Control Over Compliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition – During our testing, we noted that the reserve account was not separately identified and there was no formal review separate from the preparer over the reserve fund reconciliation for the federal program. Cause – The Organization did not have an adequate internal control policy in place to ensure the reserve account was separately tracked and a documented review and approval over the reserve fund occurred. Effect – The lack of adequate policies governing the review increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs – None reported. Context – Sampling was not used. The Organization has one reserve account that was tested. Repeat Finding from Prior Years – Yes Recommendation – We recommend that the Organization enhance internal control policies to ensure that the reserve fund is separately tracked and formal documentation of reviews are present. View of Responsible Officials – Management agrees with the finding.
Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Federal agency: Neighborhood Reinvestment Corporation (Pass-Through Grantor) Federal program title: Housing Stability Counseling Program Assistance Listing Number: 99.U19 Award Period: September 8, 2021 – April 30, 2024 • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: Uniform Grant Guidance requires compliance with the provisions of internal controls. 2 CFR Part 200.303 states that recipients of federal funds are required to establish and maintain effective internal control over the federal awards to provide reasonable assurance that the recipient of federal funds is in compliance with federal statutes, regulations and the terms and conditions of the federal award. The Foundation should have internal controls designed and effectively operating to ensure compliance with those provisions. Condition: The Foundation was not able to produce audit evidence of the review and approval of its financial and quarterly performance reports. Two out of two financial reports and three out of three quarterly performance reports did not have adequate evidence to show the reports were reviewed and approved. Questioned costs: None. Cause: The Foundation does not have policies and procedures in place to ensure formal documentation of review and approval of the financial and quarterly performance reports. Effect: The lack of effective internal controls over reporting compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend that the Foundation update its policies and procedures to ensure formal documented review and approval over financial and performance reports. Procedures must include documentation and proper sign offs from preparer and reviewer of the reports. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
2023-005 Reporting – Federal Funding Accountability and Transparency Act (FFATA) Prior Year Finding Number: N/A Year of Finding Origination: 2023 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Housing and Urban Development Program: 14.218 Community Development Block Grants/Entitlement Grants Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, that are codified in Title 2 Code of Federal Regulations, Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: Anoka County has not submitted subaward information in the FSRS as required by the FFATA for the Community Development Block Grant. Questioned Costs: None. Context: A subaward is any award provided by a pass-through entity to a subrecipient for the subrecipient to administer part of a federal award received by the pass-through entity. This issue was noted during the audit of the Community Development Block Grant; however, it impacts federal programs County-wide. Effect: Anoka County is not in compliance with FFATA reporting. Cause: The County missed HUD notifications that FFATA needed to be implemented. Recommendation: We recommend Anoka County implement procedures to complete reports required by FFATA. In addition, we recommend Anoka County work with the federal government on how best to correct reporting. View of Responsible Official: Concur