Criteria or specific requirement: 2 CFR 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures in place to ensure terminated employees are removed from the State system within a reasonable timeframe. Condition: During our testing, we noted 2 employees out of 6 tested, who were not removed from the County Benefits Management System (CBMS) within a reasonable timeframe after employment change at the County. Questioned costs: No known questioned costs. Context: During our testing over terminated users within CBMS, we noted the County did not have a compensating control in place to ensure that employees were removed from CBMS after the change in employment occurred. One employee was separated from the County in 2022, requested by the County to the State to be removed from CBMS in 2022, but was not removed from CBMS until 2023. The County did not check the employee was properly removed from the system until 2023. The second employee was terminated from the County in 2023 and was not requested by the County to the State to be removed from CBMS until 2024. Cause: The County did not have a compensating control to ensure that State accounts are offboarded when employees separate from the County or change departments that do not require them to keep their CBMS access. Effect: Employees who are terminated or no longer require access to the system, who continue to have access after termination could make changes within CBMS that impact the County’s financials and spending. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the County implement a control to ensure the State accounts are offboarded when employees separate employment or move departments that do not require them to keep CBMS access. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures in place to ensure terminated employees are removed from the State system within a reasonable timeframe. Condition: During our testing, we noted 2 employees out of 6 tested, who were not removed from the County Benefits Management System (CBMS) within a reasonable timeframe after employment change at the County. Questioned costs: No known questioned costs. Context: During our testing over terminated users within CBMS, we noted the County did not have a compensating control in place to ensure that employees were removed from CBMS after the change in employment occurred. One employee was separated from the County in 2022, requested by the County to the State to be removed from CBMS in 2022, but was not removed from CBMS until 2023. The County did not check the employee was properly removed from the system until 2023. The second employee was terminated from the County in 2023 and was not requested by the County to the State to be removed from CBMS until 2024. Cause: The County did not have a compensating control to ensure that State accounts are offboarded when employees separate from the County or change departments that do not require them to keep their CBMS access. Effect: Employees who are terminated or no longer require access to the system, who continue to have access after termination could make changes within CBMS that impact the County’s financials and spending. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the County implement a control to ensure the State accounts are offboarded when employees separate employment or move departments that do not require them to keep CBMS access. Views of responsible officials: There is no disagreement with the audit finding.
Program Affected 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2023 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria According to 2 CFR §200.303, the Organization must "establish and maintain effective internal control over the Federal award . . ." Condition and Context During tests of financial statement balances, it was determined that multiple internal controls over financial reporting were not effective which would impact federal awards. See Findings 2023-001 through 2023-008 for additional information. Cause and Effect The Organization does not have internal processes to properly identify costs related to the program. As a result, indirect costs may exceed allowable thresholds. Questioned Costs N/A Identification of Repeat Findings N/A Recommendation We recommend the Organization update its policies to implement sufficient internal controls over financial reporting to be able to properly identify costs related to the program. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2023 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria According to 2 CFR §200.303, the Organization must "establish and maintain effective internal control over the Federal award . . ." Condition and Context During tests of financial statement balances, it was determined that multiple internal controls over financial reporting were not effective which would impact federal awards. See Findings 2023-001 through 2023-008 for additional information. Cause and Effect The Organization does not have internal processes to properly identify costs related to the program. As a result, indirect costs may exceed allowable thresholds. Questioned Costs N/A Identification of Repeat Findings N/A Recommendation We recommend the Organization update its policies to implement sufficient internal controls over financial reporting to be able to properly identify costs related to the program. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2023 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria According to 2 CFR §200.303, the Organization must "establish and maintain effective internal control over the Federal award . . ." Condition and Context During tests of financial statement balances, it was determined that multiple internal controls over financial reporting were not effective which would impact federal awards. See Findings 2023-001 through 2023-008 for additional information. Cause and Effect The Organization does not have internal processes to properly identify costs related to the program. As a result, indirect costs may exceed allowable thresholds. Questioned Costs N/A Identification of Repeat Findings N/A Recommendation We recommend the Organization update its policies to implement sufficient internal controls over financial reporting to be able to properly identify costs related to the program. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. See attached Planned Corrective Actions.
2023-001 Eligibility Prior Year Finding Number: 2022-002 Year of Finding Origination: 2022 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Material Weakness and Modified Opinion Federal Agency: U.S. Department of Health and Human Services Program: 93.778 Medical Assistance Program Award Number and Year: 2305MN5ADM; 2023 Pass-Through Agency: Minnesota Department of Human Services Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The Minnesota Department of Human Services maintains the computer system, MAXIS, which is used by Sibley County to support the eligibility determination process. In the case files reviewed for eligibility, not all documentation to support participant eligibility was input into MAXIS. The following exceptions were noted in the sample of 40 MAXIS case files tested: • four case files which contained citizenship verification but citizenship in MAXIS was noted as not verified. • three case files where the asset or income listed in MAXIS did not match the documentation in the case file. Questioned Costs: None. Context: The State of Minnesota and the County split the eligibility determination process. Pursuant to Minnesota statutes, Sibley County performs the “intake function” needed for this program, while the state maintains the MAXIS system, which supports the eligibility determination process. Participants receive benefit payments from the state. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: The lack of updated information in MAXIS to document verification of key eligibility-determining factors increases the risk that program participants will receive benefits when they are not eligible. Cause: Program personnel entering case data into MAXIS reviewed the support but did not enter or update the information in the system. Recommendation: We recommend Sibley County implement additional procedures to provide reasonable assurance that the information is properly input or updated in MAXIS. View of Responsible Official: Acknowledge.
Finding 2023-001: Eligibility Documentation Information on the Federal Program: 93.566 Afghan Arrival Job Readiness Criteria or Specific Requirement: As specified in 2 CFR section 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: Upwardly Global's internal compliance controls require that each potential participant is screened to ensure that they are eligible to participate in the program prior to admission into the program. During our review of the selected participants, we noted that the documentation to support eligibility for each participant was not retained or available for review. Cause: Upwardly Global's internal compliance controls do not require that eligibility documentation for each participant be retained and available for review. Effect or Potential Effect: It is possible that Upwardly Global provided services to ineligible individuals through the program, as appropriate eligibility documentation cannot verified. Questioned Costs: None. Context: A sample of twenty participants were selected for testing. We consider our sample selection to be representative of the population. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that Upwardly Global amend their internal compliance controls to require that all supporting eligibility documentation be retained in each participant's file.
FINDING 2023-001 Subject: CDBG - Entitlement Grants Cluster - Equipment and Real Property Management Federal Agency: Department of Housing and Urban Development Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listings Number: 14.218 Federal Award Numbers and Year (or Other Identifying Numbers): B-18-MC-18-0001, B-19-MC-18-0001, B-20-MC-18-0001, B-21-MC-18-0001, B-22-MC-18-0001, B-23-MC-18-0001 Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Modified Opinion Condition and Context Community Development Block Grants/Entitlement Grants (CDBG) may be used to acquire real and personal property, supplies, and equipment. Equipment purchased with CDBG funds requires management, among other things, to maintain property records, complete a physical inventory, safeguard against loss, and properly maintain the equipment. A property record or capital asset listing, which would include the following attributes, is to be maintained for assets purchased. A description of the property. A serial number or other identification number. The source of funding for the property (including the federal award identification number FAIN). Who holds title. The acquisition date. Cost of the property. Percentage of federal participation in the project costs for the federal award under which the property was acquired. The location. Use and condition of the property. Although the City maintained property records, adequate property records for assets purchased with CDBG award funds was not maintained. The one asset purchased with CDBG funds, totaling $222,333, was added to the property records, but did not include the source of funding for the property, who holds title, percentage of federal participation, and condition of the property. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.313(d) states in part: ". . . (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." Cause A proper system of internal controls was not designed by management of the City. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the City's management of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. The City did not add an improvement as they were unaware that this should be added to the property records. In addition, the property records did not include all the necessary fields as the City did not know the additional information was needed. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, not all required elements of the property record were documented for assets acquired with CDBG award funds nor were all assets added to the property records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the City. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the City establish a proper system of internal controls and develop policies and procedures to ensure property records are maintained for all assets purchased and that all required elements are included within the property records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: U.S. Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number or Year (or Other Identifying Number): ARP Act 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 2022-001. Condition and Context During the audit period, the SLFRF program funds totaling $11,258,475 were expended under the premium pay and the water, sewer, and broadband eligible use categories. Transactions expended under the water, sewer, and broadband eligible use category, totaling $9,778,321, were subject to suspension and debarment provisions. Prior to entering into subawards and covered transactions with the SLFRF award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. The City's policies related to suspension and debarment requirements included the Executive Secretary of the Engineering and Board of Works (Executive Secretary) verifying the SAMS exclusions. The City had four ongoing contracts awarded in the prior audit period, with two vendors for various projects under the water, sewer, and broadband eligible use category. Total payments made to the vendors during the audit period were $9,778,321, all of which were subject to suspension and debarment. Per inquiry with the City, the Executive Secretary verified the two vendors were not suspended or debarred by checking the SAMs exclusions; however, retaining documentation of the verification was not part of the process. As such, we could not determine if the City complied with the suspension and debarment requirements. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you do business is not excluded or disqualified. You do this by: (a) Checking the EPLS, or (b) Collecting a certification from that person if allowed by this rule, or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not implemented by management of the City. Policies over suspension and debarment were in place; however, the procedures did not address the retention of documentation. As such, the City was unable to provide documentation to demonstrate they checked SAM.gov to verify that contractors were not suspended or debarred prior to payment. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, no documentation was retained to show the status of vendors to whom payments equal to or in excess of $25,000 were made. Program funds used to pay contractors that have been suspended or debarred would be unallowable and the funding agency could potentially recovery them. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the City. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the City strengthen its system of internal controls to ensure that all contractors that are paid $25,000 or more, all in or in part with federal funds, are not suspended or debarred from participating in federal programs. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for federal programs is retained to be present for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-002 Subject: CDBG - Entitlement Grants Cluster - Reporting Federal Agency: Department of Housing and Urban Development Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listings Number: 14.218 Federal Award Numbers and Years (or Other Identifying Numbers): B-18-MC-180004, B-19-MC-180004, B-20-MC-180004, B-21-MC-180004, B-22-MC-180004, B-23-MC-180004 Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context Recipients are required to submit quarterly the CDBG Cash on Hand Quarterly report (PR29). The report is generated from information entered by the City into HUD's Integrated Disbursement Information System (IDIS). The City did not have internal control procedures in place over the PR29 Quarterly Reports. The reports were generated and submitted by one individual, without a review or oversight process to detect and correct errors. The lack of internal controls was isolated to the quarterly reports noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A proper system of internal controls was not designed by the management of the City. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the City's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls over reporting, the City cannot ensure that the reports submitted are materially accurate and correct. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the management of the City design and implement a proper system of internal controls, including a segregation of duties, to ensure the accuracy and correctness of the PR 29 reports. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Department of Homeland Security, State of Nebraska Office of Emergency Management Agency, 97.039, DR‐4420‐NE‐0017 Hazard Mitigation Grant Program Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Significant Deficiency 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 the terms and conditions of the federal award. Condition: There was one instance of an employee’s timesheet which did not have an independent review performed. Cause: The timesheet was reviewed and approved by the same employee who performed the work on the grant. The timesheet will get reviewed as a part of month end close, however, there is no documentation supporting a formally documented review or approval over payroll. Effect: The District’s control procedures did not detect or correct the error. Questioned Costs: No questioned costs over $25,000. Context/Sampling: Nonstatistical sampling was used. Sample size of 15 transactions which accounted for $2,196,234 out of $2,216,216 of federal program expenditures of which $1,662,162 was submitted for reimbursement. Repeat Finding form Prior Year: No Recommendation: We recommend the District review the employee timesheet approval process to ensure that all timesheets are obtaining an independent review and approval. Views of Responsible Officials: Management agrees with the finding.
Department of Homeland Security, State of Nebraska Office of Emergency Management Agency, 97.039, DR‐4420‐NE‐0017 Hazard Mitigation Grant Program Reporting Significant Deficiency 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 the terms and conditions of the federal award. Condition: Certain line items in the reports submitted for the quarters ended 6/30/2023 and 9/30/2023 contained costs from the incorrect period. Cause: The District utilized the “Job Analysis Report” and was unaware the report contained costs that were from the incorrect period. Effect: The District’s control process and procedures did not detect or correct the errors. Questioned Costs: No questioned costs over $25,000. Context/Sampling: Nonstatistical sampling was used. There were four quarterly reports submitted throughout the fiscal year. As such, two reports were selected for testing. Key line items were identified within the reports for testing. Repeat Finding form Prior Year: No Recommendation: We recommend the District review the process surrounding the data utilized to put together the quarterly reports submitted to ensure the correct amounts are used and are properly supported. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: COVID-19 Community Development Block Grants/State’s Program and Non- Entitlement Grants in Hawaii Assistance Listing Number: 14.228 Federal Award Identification Number and Year: B-20-DW-27-0001, 2023 Pass-Through Agency: Minnesota Department of Employment and Economic Development, Business and Community Development Division Pass-Through Number: B-20-DW-27-0001 Compliance Requirement Affected: Reporting Award Period: Year Ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Recipients of $150,000 or more of grant funds must submit a quarterly and annual report, no later than 7 days after the end of each calendar quarter and 15 days after the fiscal year end, respectively. Quarterly and annual reports must be in accordance with reporting requirements set forth in section 15011 of the CARES Act. The Grantee will monitor the activities of the sub-recipient according to 2 CFR §200.303 and 2 CFR §200.331 as necessary to ensure that the sub-award is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the sub-award; and that sub-award performance goals are achieved. This includes reviewing financial and programmatic reports required by the pass-through entity. Condition: There was no oversight by County management of the reports being submitted by the subrecipient to the State. Questioned Costs: None noted. Context: For two of two quarterly reports and one of one annual reports tested, it was noted that there was no review by County management of the reports submitted by the subrecipient and the County received a copy of the report at the same time as the submission was completed. Cause: Insufficient management oversight. Effect: Ineligible costs could be reported. Repeat Finding: No. Recommendation: We recommend that the County reviews their policies to ensure reporting requirements are met including a review of the subrecipient reports prior to submission. Views of responsible officials: There is no disagreement with the audit finding.
2023-001 FFATA Reporting 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. Department of Housing and Urban Development Program: 14.218 Community Development Block Grant Award Number and Year: B-16-MC-27-0003, 2016; B-17-MC-27-0003, 2017; B-18-MC-27-0003, 2018; B-19-MC-27-0003, 2019; B-20-MC-27-003, 2020; B-20-MW-27-003, 2020; B-21-MC-27-0003, 2021; B-22-MC-27-0003, 2022; B-23-MC-27-0003, 2023 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 (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, that are codified in Title 2 U.S. 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) no later than the month following the month in which the obligation was made. Condition: The City reported subawards related to the 2023 Community Development Block Grant (CDBG) award in an annual report in March 2024 when the documentation was requested for audit. Questioned Costs: None. Context: The City has filed annual FFATA reports for CDBG grants years 2020 through 2023, including 2020CV. Effect: The City is not in compliance with FFATA reporting requirements. Cause: We were informed the federal awarding agency did not immediately load the City’s 2023 CDBG award into FSRS. City staff initially monitored FSRS on a monthly basis; however, monitoring efforts were not maintained. Upon this information being requested for audit purposes, City staff verified the award had been loaded into FSRS and submitted the report. Recommendation: We recommend the City implement procedures to ensure reports are submitted as required by FFATA. View of Responsible Official: Concur
2023-001 FFATA Reporting 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. Department of Housing and Urban Development Program: 14.218 Community Development Block Grant Award Number and Year: B-16-MC-27-0003, 2016; B-17-MC-27-0003, 2017; B-18-MC-27-0003, 2018; B-19-MC-27-0003, 2019; B-20-MC-27-003, 2020; B-20-MW-27-003, 2020; B-21-MC-27-0003, 2021; B-22-MC-27-0003, 2022; B-23-MC-27-0003, 2023 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 (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, that are codified in Title 2 U.S. 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) no later than the month following the month in which the obligation was made. Condition: The City reported subawards related to the 2023 Community Development Block Grant (CDBG) award in an annual report in March 2024 when the documentation was requested for audit. Questioned Costs: None. Context: The City has filed annual FFATA reports for CDBG grants years 2020 through 2023, including 2020CV. Effect: The City is not in compliance with FFATA reporting requirements. Cause: We were informed the federal awarding agency did not immediately load the City’s 2023 CDBG award into FSRS. City staff initially monitored FSRS on a monthly basis; however, monitoring efforts were not maintained. Upon this information being requested for audit purposes, City staff verified the award had been loaded into FSRS and submitted the report. Recommendation: We recommend the City implement procedures to ensure reports are submitted as required by FFATA. View of Responsible Official: Concur
2023-002 Suspension and Debarment and Build America, Buy America Act 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. Department of Transportation Program: 20.205 Highway Planning and Construction 20.205 COVID-19 - Highway Planning and Construction Award Number and Year: Not provided, 2023 Pass-Through Agency: Minnesota Department of Transportation Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction. The suspension and debarment requirements apply to covered transaction amounts over $25,000. The City’s procurement policy requires a suspension and debarment clause be included in the contract and also requires the contract manager to verify the vendor is not suspended, debarred, or otherwise excluded at SAM.gov. Additionally, section 70914 of the Build America, Buy America Act (BABA), requires a Buy America preference be included in the terms and conditions of each award with an infrastructure project. Condition: The contract in one of four projects tested did not include the suspension and debarment clause or the BABA preference. In addition, the City did not verify suspension and debarment before entering into the contract. Questioned Costs: None. Context: Four of eight contracts were tested for compliance with applicable federal regulations. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Failure to verify vendors are not suspended, debarred, or otherwise excluded may result in the City entering into a transaction with a vendor that is not authorized to provide goods and services. Also, failure to include the BABA requirements in the contract may result in construction materials used in the project not complying with the requirement of the BABA. Cause: Federal requirements were not followed as the project was initially planned without the use of federal funds. Recommendation: We recommend the City review its written policies and procedures and communicate with contract managers/administrators their responsibility for complying with the federal regulations and maintaining documentation to support that compliance. View of Responsible Official: Concur
2023-002 Suspension and Debarment and Build America, Buy America Act 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. Department of Transportation Program: 20.205 Highway Planning and Construction 20.205 COVID-19 - Highway Planning and Construction Award Number and Year: Not provided, 2023 Pass-Through Agency: Minnesota Department of Transportation Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction. The suspension and debarment requirements apply to covered transaction amounts over $25,000. The City’s procurement policy requires a suspension and debarment clause be included in the contract and also requires the contract manager to verify the vendor is not suspended, debarred, or otherwise excluded at SAM.gov. Additionally, section 70914 of the Build America, Buy America Act (BABA), requires a Buy America preference be included in the terms and conditions of each award with an infrastructure project. Condition: The contract in one of four projects tested did not include the suspension and debarment clause or the BABA preference. In addition, the City did not verify suspension and debarment before entering into the contract. Questioned Costs: None. Context: Four of eight contracts were tested for compliance with applicable federal regulations. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Failure to verify vendors are not suspended, debarred, or otherwise excluded may result in the City entering into a transaction with a vendor that is not authorized to provide goods and services. Also, failure to include the BABA requirements in the contract may result in construction materials used in the project not complying with the requirement of the BABA. Cause: Federal requirements were not followed as the project was initially planned without the use of federal funds. Recommendation: We recommend the City review its written policies and procedures and communicate with contract managers/administrators their responsibility for complying with the federal regulations and maintaining documentation to support that compliance. View of Responsible Official: Concur
2023-002 Suspension and Debarment and Build America, Buy America Act 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. Department of Transportation Program: 20.205 Highway Planning and Construction 20.205 COVID-19 - Highway Planning and Construction Award Number and Year: Not provided, 2023 Pass-Through Agency: Minnesota Department of Transportation Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction. The suspension and debarment requirements apply to covered transaction amounts over $25,000. The City’s procurement policy requires a suspension and debarment clause be included in the contract and also requires the contract manager to verify the vendor is not suspended, debarred, or otherwise excluded at SAM.gov. Additionally, section 70914 of the Build America, Buy America Act (BABA), requires a Buy America preference be included in the terms and conditions of each award with an infrastructure project. Condition: The contract in one of four projects tested did not include the suspension and debarment clause or the BABA preference. In addition, the City did not verify suspension and debarment before entering into the contract. Questioned Costs: None. Context: Four of eight contracts were tested for compliance with applicable federal regulations. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Failure to verify vendors are not suspended, debarred, or otherwise excluded may result in the City entering into a transaction with a vendor that is not authorized to provide goods and services. Also, failure to include the BABA requirements in the contract may result in construction materials used in the project not complying with the requirement of the BABA. Cause: Federal requirements were not followed as the project was initially planned without the use of federal funds. Recommendation: We recommend the City review its written policies and procedures and communicate with contract managers/administrators their responsibility for complying with the federal regulations and maintaining documentation to support that compliance. View of Responsible Official: Concur
2023-003 Procurement, Suspension, and Debarrment 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. Department of the Treasury Program: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: SLT0790, 2021; E-20-MW-27-0003, 2020 Pass-Through Agency: Minnesota Department of Health Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 2 U.S. Code of Federal Regulations § 200.318(i) states that the City must maintain records sufficient to detail the history of procurement, and the City must perform a cost or price analysis provided in Title 2 U.S. Code of Federal Regulations § 200.323. In addition, federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction. The suspension and debarment requirements apply to covered transaction amounts over $25,000. Entities must use their documented procurement process compliance. The City’s procurement policy requires a suspension and debarment clause be included in the contract and also requires the contract manager to verify the vendor is not suspended, debarred, or otherwise excluded at SAM.gov. Condition: Five of the nine contracts tested exceeded the simplified acquisition threshold which requires a cost or price analysis. The City could not provide documentation that this analysis was performed for four contracts tested. Additionally, a sample of 20 covered transactions was tested for suspension and debarment. In two instances, the City included required suspension and debarment contract clauses but did not maintain documentation of the verification that the vendor was not suspended or debarred at SAM.gov. Questioned Costs: None. Context: Nine of 89 contracts were tested for compliance with applicable federal regulations. Additionally, there were 191 covered transactions subject to suspension and debarment. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: The City is not in compliance with federal regulations. Cause: Project/contract managers did not perform or maintain documentation of cost or price analyses. The project/contract managers did not know verification of suspension and debarment using the federal listing was required and, in one instance, relied on the state listing. Recommendation: We recommend the City review its written policies and procedures and communicate with contract managers their responsibility for complying with the federal regulations and maintaining documentation to support that compliance. View of Responsible Official: Concur
2023-003 Procurement, Suspension, and Debarrment 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. Department of the Treasury Program: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: SLT0790, 2021; E-20-MW-27-0003, 2020 Pass-Through Agency: Minnesota Department of Health Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 2 U.S. Code of Federal Regulations § 200.318(i) states that the City must maintain records sufficient to detail the history of procurement, and the City must perform a cost or price analysis provided in Title 2 U.S. Code of Federal Regulations § 200.323. In addition, federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction. The suspension and debarment requirements apply to covered transaction amounts over $25,000. Entities must use their documented procurement process compliance. The City’s procurement policy requires a suspension and debarment clause be included in the contract and also requires the contract manager to verify the vendor is not suspended, debarred, or otherwise excluded at SAM.gov. Condition: Five of the nine contracts tested exceeded the simplified acquisition threshold which requires a cost or price analysis. The City could not provide documentation that this analysis was performed for four contracts tested. Additionally, a sample of 20 covered transactions was tested for suspension and debarment. In two instances, the City included required suspension and debarment contract clauses but did not maintain documentation of the verification that the vendor was not suspended or debarred at SAM.gov. Questioned Costs: None. Context: Nine of 89 contracts were tested for compliance with applicable federal regulations. Additionally, there were 191 covered transactions subject to suspension and debarment. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: The City is not in compliance with federal regulations. Cause: Project/contract managers did not perform or maintain documentation of cost or price analyses. The project/contract managers did not know verification of suspension and debarment using the federal listing was required and, in one instance, relied on the state listing. Recommendation: We recommend the City review its written policies and procedures and communicate with contract managers their responsibility for complying with the federal regulations and maintaining documentation to support that compliance. View of Responsible Official: Concur
2023-003 Procurement, Suspension, and Debarrment 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. Department of the Treasury Program: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: SLT0790, 2021; E-20-MW-27-0003, 2020 Pass-Through Agency: Minnesota Department of Health Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 2 U.S. Code of Federal Regulations § 200.318(i) states that the City must maintain records sufficient to detail the history of procurement, and the City must perform a cost or price analysis provided in Title 2 U.S. Code of Federal Regulations § 200.323. In addition, federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction. The suspension and debarment requirements apply to covered transaction amounts over $25,000. Entities must use their documented procurement process compliance. The City’s procurement policy requires a suspension and debarment clause be included in the contract and also requires the contract manager to verify the vendor is not suspended, debarred, or otherwise excluded at SAM.gov. Condition: Five of the nine contracts tested exceeded the simplified acquisition threshold which requires a cost or price analysis. The City could not provide documentation that this analysis was performed for four contracts tested. Additionally, a sample of 20 covered transactions was tested for suspension and debarment. In two instances, the City included required suspension and debarment contract clauses but did not maintain documentation of the verification that the vendor was not suspended or debarred at SAM.gov. Questioned Costs: None. Context: Nine of 89 contracts were tested for compliance with applicable federal regulations. Additionally, there were 191 covered transactions subject to suspension and debarment. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: The City is not in compliance with federal regulations. Cause: Project/contract managers did not perform or maintain documentation of cost or price analyses. The project/contract managers did not know verification of suspension and debarment using the federal listing was required and, in one instance, relied on the state listing. Recommendation: We recommend the City review its written policies and procedures and communicate with contract managers their responsibility for complying with the federal regulations and maintaining documentation to support that compliance. View of Responsible Official: Concur
FINDING 2023-002 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 Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-004. Condition and Context The County had not properly designated or implemented a system of internal controls, which would include appropriate segregation of duties that would likely be effective in preventing, or detecting and correcting, noncompliance. A single employee prepared and submitted reports without a documented review or oversight process in place to prevent, or detect and correct, errors. Recipients are required to submit quarterly or annual Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon the 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 metropolitan county with a population below 250,000 residents that received an allocation of more than $10 million in State and Local Fiscal Recovery Funds (SLFRF). As such, the initial P&E report covering three calendar quarters from March 3, 2021 to December 31, 2021, was required to be submitted to the Treasury by January 31, 2022. The subsequent quarterly reports are to cover one calendar quarter and must be submitted to the Treasury by the last day of the month following the end of the period covered. INDIANA STATE BOARD OF ACCOUNTS 18 BOONE COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The County submitted three P&E reports during the audit period. No report was submitted for the period of October 1, 2022 to December 31, 2022, although there was activity during this time period. For the three reports submitted, all activity for the reporting period was not included, and the reports were not fairly presented. Errors identified included the following: Quarter 1 report (January 1, 2023 to March 31, 2023) Total Cumulative Obligations and Total Cumulative Expenditures were understated by $399,741. Current Period Obligations and Current Period Expenditures were understated by $58,730. Quarter 2 report (April 1, 2023 to June 30, 2023) Total Cumulative Obligations and Current Period Expenditures were understated by $968,137. Current Period Obligations and Current Period Expenditures were understated by $558,396. Quarter 3 report (July 1, 2023 to September 30, 2023) Total Cumulative Obligations and Total Cumulative Expenditures were understated by $1,325,566. Current Period Obligations and Current Period Expenditures were understated by $357,429. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 31 CFR 35.4(c) states in part: "Reporting and requests for other information. During the period of performance, recipients shall provide to the Secretary periodic reports providing detailed accounting of the uses of funds, . . ." INDIANA STATE BOARD OF ACCOUNTS 19 BOONE COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, page 10, states in part: ". . . 10. Reporting. All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. . . ." Cause A proper system of internal controls over the P&E reports was not designed by management of the County. The County was unable to provide documentation that a proper review of the P&E reports showing a reconciliation between amounts reported and amounts expended from federal funds was done prior to submission of the report. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the County's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the County cannot ensure reports are filed and that filed reports accurately report their SLFRF activity. As such, the County's SLFRF obligations and expenditures were not appropriately reported to the Treasury. In addition to not meeting the SLFRF reporting requirements, this increases the likelihood that the public will not have access to transparent and accurate information regarding expenditures of federal awards. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. 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 to ensure that all reports are filed with the Treasury. Additionally, management should develop policies and procedures to ensure that information provided to the Treasury is complete and accurate. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Subrecipient Monitoring 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: Subrecipient Monitoring 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 2022-005. Condition and Context The County received a total State and Local Fiscal Recovery Funds (SLFRF) allocation of $13,177,707. During the audit period, the County provided subawards of SLFRF funds to other entities. As a pass-through entity, the County must: Identify the award and the applicable requirements to each subrecipient. Evaluate each subrecipient's risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for an authorized purpose, complies with the terms and conditions of the subaward, and achieves performance goals. Subawards, totaling $290,000, were provided to two different entities. Both subrecipient agreements associated with the subawards were selected for testing. For the two agreements tested, the following information was incomplete or missing: The federal award identification number (FAIN). The federal award date of award to the recipient by the federal agency. The name of the federal awarding agency, pass-through entity (auditee), and contact information for awarding official of the pass-through entity (auditee). The Assistance Listings Number and Title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listings Number at time of disbursement. Furthermore, the County did not have an evaluation of the subrecipients' risk of noncompliance or monitoring activities demonstrating compliance with the subrecipient monitoring requirement. The County did not request any financial or audit documentation from the subrecipients. The lack of internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 21 BOONE COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.331(a) states: "Subrecipients. A subaward is for the purpose of carrying out a portion of a Federal award and creates a Federal assistance relationship with the subrecipient. See definition for Subaward in § 200.1 of this part. Characteristics which support the classification of the non-Federal entity as a subrecipient include when the non-Federal entity: (1) Determines who is eligible to receive what Federal assistance; (2) Has its performance measured in relation to whether objectives of a Federal program were met; (3) Has responsibility for programmatic decision-making; (4) Is responsible for adherence to applicable Federal program requirements specified in the Federal award; and (5) In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose specified in authorizing statute, as opposed to providing goods or services for the benefit of the pass-through entity." 2 CFR 200.332 states in part: "All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward . . . (1) Federal award identification. (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; INDIANA STATE BOARD OF ACCOUNTS 22 BOONE COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the passthrough entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the passthrough entity; (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (4) (i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the passthrough entity must determine the appropriate rate in collaboration with the subrecipient, which is either: (A) The negotiated indirect cost rate between the pass-through entity and the subrecipient; which can be based on a prior negotiated rate between a different PTE and the same subrecipient. If basing the rate on a previously negotiated rate, the pass-through entity is not required to collect information justifying this rate, but may elect to do so; (B) The de minimis indirect cost rate. INDIANA STATE BOARD OF ACCOUNTS 23 BOONE COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. Subrecipients can elect to use the cost allocation method to account for indirect costs in accordance with § 200.405(d). (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. (b) Evaluate each subrecipient's risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determined the appropriate subrecipient monitoring . . . (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (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 pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. . . ." Cause The system of internal controls as established by the management of the County was not properly designed nor implemented. The County was unable to provide documentation that monitoring procedures were in place over subrecipients. Effect Without the proper implementation of an effectively designed system of internal controls, the County cannot be sure subrecipients are provided an adequate subaward agreement, with all required elements and are adequately monitored. As such, subaward agreements entered into by the County did not include all the required elements. In addition, the County did not properly monitor the non-profit to ensure proper spending of the federal funds. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. INDIANA STATE BOARD OF ACCOUNTS 24 BOONE COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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 and develop policies and procedures to ensure subrecipients are provided with an adequate subaward agreement and monitored as appropriate. 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 - Procurement and 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): FY2023 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 for suspension and debarment. The prior audit finding number was 2022-003. Condition and Context Procurement - Policy The County did not have a County Council approved procurement policy that would reflect applicable state laws and regulations, including procedures to avoid acquisition of unnecessary or duplicative items and procedures to ensure that all solicitations incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured. Procurement - Small Purchases Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a nonfederal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $50,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. INDIANA STATE BOARD OF ACCOUNTS 25 BOONE COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The County had five vendors that qualified for testing under small purchase procurement requirements (vendors paid $10,000-$150,000). Of the two chosen for testing, one was awarded a contract without the County obtaining quotes. The contract awarded was $31,000 for engineering services related to drain construction. The lack of effective internal controls and noncompliance was isolated to the small purchase identified above. Suspension and Debarment Prior to entering into subawards and covered transactions with State and Local Fiscal Recovery Funds (SLFRF), recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Due to the U.S. Department of the Treasury's (Treasury) 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, in order to review the 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, the County explained they were aware of the suspension and debarment requirements related to the SLFRF awards; however, the County did not retain documentation of SAMs.gov checks nor was a clause always included in a contract. A population of ten covered transactions for goods or services, totaling $2,371,047, that equaled or exceeded $25,000 paid from SLFRF funds during the audit period was identified. A sample of three transactions, totaling $1,473,295, was selected for testing. For each of the three transactions, the County did not verify the vendors' suspension and debarment status prior to payment. Due to the number and magnitude of exceptions identified, per auditor judgment, we concluded it would not be appropriate to expand the sample size or perform any additional audit procedures. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 26 BOONE COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.318 states: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases — (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." 2 CFR 200.214 states: "Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are de-barred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities." 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 INDIANA STATE BOARD OF ACCOUNTS 27 BOONE COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (c) Adding a clause or condition to the covered transaction with that person." Part 4 of the Treasury's Compliance and Reporting Guidance states in part: ". . . recipients are expected to have procurement policies and procedures in place that comply with the procurement standards outlined in the Uniform Guidance . . ." Cause A proper system of internal controls was not designed by the management of the County. The County was unable to provide documentation to demonstrate it checked SAM.gov to verify that contractors and vendors were not suspended or debarred. The County was also unable to provide documentation explaining the rationale behind decisions to offer contracts without obtaining an adequate number of bids or quotes. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the County's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, one small purchase did not have an adequate number of quotes. In addition, vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation We recommended the County establish documented procurement procedures consistent with state and local laws for the acquisition of property or services required under a federal award or subaward as outlined in the code of federal regulations. In addition, we recommended the County adhere to the procurement policies and obtain required quotes and bids or adequately document a sole source situation. Finally, 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 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and 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): FY2023 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into subawards and covered transactions with the State and Local Fiscal Recovery Funds (SLFRF) award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a non-procurement transaction (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 (EPLS), collecting a certification from that party, or adding a clause or condition to the covered transaction with that person. The City did not have any policies or procedures in place related to the suspension and debarment requirements. A population of two covered transactions, totaling $109,024, associated with the Chemical Phosphorous Removal Improvements project paid from SLFRF funds were identified. Both vendors associated with the covered transactions were selected for testing. For both vendors, the City did not verify the vendors' suspension or debarment status prior to payment. The lack of internal controls and noncompliance were isolated to the transactions identified above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 18 CITY OF RENSSELAER 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 City's purchasing policy does not provide procedures on how to ensure compliance with the suspension and debarment requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the City cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any program funds the City used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the City design and implement a system of internal controls to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended, debarred, or otherwise excluded from participating in federal programs prior to entering into any contracts. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. INDIANA STATE BOARD OF ACCOUNTS 19
Federal Program AL No. 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Pass-through Entity State of Delaware Federal Agency U.S. Department of Treasury Contract Number and Award Year Award Number SLFRP0139 Award year March 3, 2021 through December 31, 2026 Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition and Context Nemours failed to timely report their quarterly expenditures to the State of Delaware for the fourth quarter of 2023, as agreed to in their contractual agreement. Possible Cause and Effect There was an absence of internal controls in place to ensure that the grant was being appropriately monitored, including the contractual reporting requirements. Questioned Costs None Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat of Prior Finding No Recommendations Management should enhance its process to ensure an appropriate individual is assigned responsibility for monitoring all contractual aspects of the grant, including the reporting requirements. View of Responsible Officials Management agrees with the noted finding.
Federal Program Research and Development Cluster Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition and Context The Harmony payroll system is configured to calculate and apply salary cap limits to payroll related expenditures allocated to federally funded Research & Development programs in accordance with National Institute of Health (NIH) guidelines. This limit is applied based on employees’ hourly salary rates (calculated as gross annual pay divided by 2,080 hours for salaried employees). In testing a sample of 60 payroll expenditures, KPMG identified two employees whose calculated payroll expenditure exceeded the amount that should have been recorded due to incorrect inputs utilized in the calculation of the salary cap limits within the Harmony payroll system. The employees affected were non-full time (non-FTE) employees who, while salaried, do not work 2,080 hours per year. When calculating the salary cap limits for these employees, the non-FTE status was not considered, resulting in a lower hourly salary rate being utilized in applying the salary cap limit. Possible Cause and Effect The Harmony payroll system was not configured to appropriately apply salary cap thresholds to non-FTE status employees. Questioned Costs $15,834 Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat of Prior Finding No Recommendations The Foundation should update the configuration of the Harmony payroll system to properly consider the FTE status of employees when calculating salary cap limits for employees expending time and effort on federally funded programs. View of Responsible Officials Management agrees with the noted finding.
Federal Program Research and Development Cluster Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition and Context The Harmony payroll system is configured to calculate and apply salary cap limits to payroll related expenditures allocated to federally funded Research & Development programs in accordance with National Institute of Health (NIH) guidelines. This limit is applied based on employees’ hourly salary rates (calculated as gross annual pay divided by 2,080 hours for salaried employees). In testing a sample of 60 payroll expenditures, KPMG identified two employees whose calculated payroll expenditure exceeded the amount that should have been recorded due to incorrect inputs utilized in the calculation of the salary cap limits within the Harmony payroll system. The employees affected were non-full time (non-FTE) employees who, while salaried, do not work 2,080 hours per year. When calculating the salary cap limits for these employees, the non-FTE status was not considered, resulting in a lower hourly salary rate being utilized in applying the salary cap limit. Possible Cause and Effect The Harmony payroll system was not configured to appropriately apply salary cap thresholds to non-FTE status employees. Questioned Costs $15,834 Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat of Prior Finding No Recommendations The Foundation should update the configuration of the Harmony payroll system to properly consider the FTE status of employees when calculating salary cap limits for employees expending time and effort on federally funded programs. View of Responsible Officials Management agrees with the noted finding.
Federal Program Research and Development Cluster Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition and Context The Harmony payroll system is configured to calculate and apply salary cap limits to payroll related expenditures allocated to federally funded Research & Development programs in accordance with National Institute of Health (NIH) guidelines. This limit is applied based on employees’ hourly salary rates (calculated as gross annual pay divided by 2,080 hours for salaried employees). In testing a sample of 60 payroll expenditures, KPMG identified two employees whose calculated payroll expenditure exceeded the amount that should have been recorded due to incorrect inputs utilized in the calculation of the salary cap limits within the Harmony payroll system. The employees affected were non-full time (non-FTE) employees who, while salaried, do not work 2,080 hours per year. When calculating the salary cap limits for these employees, the non-FTE status was not considered, resulting in a lower hourly salary rate being utilized in applying the salary cap limit. Possible Cause and Effect The Harmony payroll system was not configured to appropriately apply salary cap thresholds to non-FTE status employees. Questioned Costs $15,834 Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat of Prior Finding No Recommendations The Foundation should update the configuration of the Harmony payroll system to properly consider the FTE status of employees when calculating salary cap limits for employees expending time and effort on federally funded programs. View of Responsible Officials Management agrees with the noted finding.
Federal Program Research and Development Cluster Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition and Context The Harmony payroll system is configured to calculate and apply salary cap limits to payroll related expenditures allocated to federally funded Research & Development programs in accordance with National Institute of Health (NIH) guidelines. This limit is applied based on employees’ hourly salary rates (calculated as gross annual pay divided by 2,080 hours for salaried employees). In testing a sample of 60 payroll expenditures, KPMG identified two employees whose calculated payroll expenditure exceeded the amount that should have been recorded due to incorrect inputs utilized in the calculation of the salary cap limits within the Harmony payroll system. The employees affected were non-full time (non-FTE) employees who, while salaried, do not work 2,080 hours per year. When calculating the salary cap limits for these employees, the non-FTE status was not considered, resulting in a lower hourly salary rate being utilized in applying the salary cap limit. Possible Cause and Effect The Harmony payroll system was not configured to appropriately apply salary cap thresholds to non-FTE status employees. Questioned Costs $15,834 Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat of Prior Finding No Recommendations The Foundation should update the configuration of the Harmony payroll system to properly consider the FTE status of employees when calculating salary cap limits for employees expending time and effort on federally funded programs. View of Responsible Officials Management agrees with the noted finding.
Federal Program Research and Development Cluster Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition and Context The Harmony payroll system is configured to calculate and apply salary cap limits to payroll related expenditures allocated to federally funded Research & Development programs in accordance with National Institute of Health (NIH) guidelines. This limit is applied based on employees’ hourly salary rates (calculated as gross annual pay divided by 2,080 hours for salaried employees). In testing a sample of 60 payroll expenditures, KPMG identified two employees whose calculated payroll expenditure exceeded the amount that should have been recorded due to incorrect inputs utilized in the calculation of the salary cap limits within the Harmony payroll system. The employees affected were non-full time (non-FTE) employees who, while salaried, do not work 2,080 hours per year. When calculating the salary cap limits for these employees, the non-FTE status was not considered, resulting in a lower hourly salary rate being utilized in applying the salary cap limit. Possible Cause and Effect The Harmony payroll system was not configured to appropriately apply salary cap thresholds to non-FTE status employees. Questioned Costs $15,834 Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat of Prior Finding No Recommendations The Foundation should update the configuration of the Harmony payroll system to properly consider the FTE status of employees when calculating salary cap limits for employees expending time and effort on federally funded programs. View of Responsible Officials Management agrees with the noted finding.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.
Federal Agency U.S. Department of Health and Human Services Criteria 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, 2 CFR section 200.510 requires the auditee 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 as determined in accordance with 2 CFR section 200.502. Condition and Context In preparing the SEFA, Nemours management adjusted general ledger amounts for payroll adjustments recorded in the general ledger in fiscal year 2024 that related to fiscal year 2023 expenditures. These manual adjustments, were not material to the 2023 combined financial statements and related to correcting allocations of time and effort charged to federal grants. Through our allowability testing of payroll expenditures within the Research & Development Cluster, we determined the impact of these time and effort payroll corrections was not completely captured during the SEFA preparation process. As a result, adjustments to the SEFA were made of approximately $617,000. Possible Cause and Effect Because effort reporting changes were not timely identified and processed prior to the closing of the books and records for the fiscal year, there were payroll related changes impacting federal grants that were processed in the general ledger during 2024. As a result, management attempted to identify all of these changes and manually adjust the SEFA accordingly. Due to the manual nature of the process, a portion of the 2024 corrections which impacted the 2023 expenditures were not completely captured during the SEFA preparation process. Questioned Costs None Statistically Valid Sample Not applicable Repeat of Prior Finding No Recommendations Management should revise its process to ensure that effort reporting changes are timely identified and processed in the appropriate period. Additionally, should changes be identified subsequent to year end, the process to identify manual adjustments to the SEFA, if any, should be reviewed for completeness. View of Responsible Officials Management agrees with the noted finding. Management notes that all payroll adjustments were completed prior to reporting any final costs to the funding agencies.