2023-006 – Allowable Costs Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 9/1/23-8/31/25; 4/1/21-3/31/23; 6/1/19-5/31/23; 6/1/23-5/31/26; 12/1/22-5/31/23 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement: § 200.303(a) indicates non-federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Organization could not provide supporting documentation showing management's review and approval of costs totaling $511 for camera supplies. Questioned Costs: None. Context: Of the three transactions selected for testing, there was no documentation available to support management's review and approval of one transaction. Cause: Management turnover. Effect: If costs are not reviewed and approved as being allowable, it could result in unallowable costs being charged to federal grants. Repeat Finding: No. Recommendation: We recommend the Organization maintain approvals electronically within Intacct. Views of Responsible Officials: There is no disagreement with the audit finding.
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.318 through 200.317 which also requires documentation to be retained to detail the history of procurements. Condition: The organization has not adopted a procurement policy containing required provisions in accordance with 2 CFR 200.318. For each of the 5 vendors selected for testing there was no documentation retained to support the rationale for the method of procurement. Additionally, the Organization did not consider whether the vendor was suspended or debarred from doing business with the federal government prior to entering the covered transaction for each of the 5 vendors selected for testing. Cause: The Organization has not adopted a procurement policy resulting in the lack of established internal controls over the procurement process. Effect: Without a written procurement policy in accordance with the Uniform Guidance, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Questioned Costs: None reported based on assessment of comparative pricing readily available. Context/Sampling: A nonstatistical sample of 5 vendors out of 15 vendors were selected for testing. Repeat Finding from Prior Year: No. Recommendation: We recommend management review 2 CFR 200.318 through 200.327 and adopt a procurement policy containing all required provisions including provisions to check for suspension and debarment. Views of Responsible Officials: Management is in agreement.
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.328 and 2 CFR 200.329 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with the program requirements. Condition: Of three reports tested, two instances in which support was not retained to substantiate federal share of expenditures reported in a quarterly report and the final report. Management subsequently worked to reconcile reports out of the Organization’s accounting software to support federal expenditures reported within the reports that materially agree. Additionally, individual who prepared the report is the same individual approving the report prior to submission to the federal agency. Cause: Support was not retained to substantiate amounts reported within a semi-annual report and final report. Additionally, management hasn’t implemented controls ensuring the individual preparing the report is separate from the individual who reviews and approves the report prior to submission to the federal agency. Effect: Without retaining documentation to support the amounts reported, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Additionally, not having a formal oversight process over reporting results in a reasonable possibility that reports that are inaccurate or incomplete could be submitted. Questioned Costs: None reported. Context/Sampling: Two out of four semi-annual financial reports were reviewed along with one annual financial report. There was a total of five financial reports filed. Repeat Finding from Prior Year: No.
Criteria: The Organization is required to have procedures in place to ensure that federal awards are expended only for allowable costs in accordance with Subpart E – Cost Principles of the Uniform Guidance. Allowable costs are supported by appropriate documentation and correctly charged as to account, amount, and period. 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. 2 CFR 200.430(i) establishes the standards for documentation of personnel expenses including charges to Federal awards for salaries and wages. Charges must be based on records that accurately reflect the work performed with the records meeting the following standards: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. b) Be incorporated into the official records of the non-Federal entity. c) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities. d) Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy. e) Comply with the established accounting policies and practices of the non-Federal entity. f) Support the distribution of the employee’s salary or wages among specific activities or cost objectives. g) Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: Through testing over payroll expenditures management could not provide support to substantiate the rate of pay paid to one employee was approved by the President or Board of Directors. Additionally, six instances identified in which the employee’s wages that were billed to the federal award were billed at a higher hourly rate than the employee’s hourly rate with the Organization. Cause: There was a lapse in oversight of the internal control process ensuring management retained support of President or Board of Directors approval of employee’s salary. Effect: The Organization’s controls did not detect or correct the errors identified, which results in a reasonable possibility that the Organization could submit disallowed costs under the federal awards. Questioned Costs: No questioned costs over $25,000. Context/Sampling: A nonstatistical sample of 29 payroll transactions out of approximately 144 total payroll transactions, accounting for approximately $36,400 of $140,200 total payroll costs charged to federal program. Repeat Finding from Prior Year: No. Recommendation: We recommend management to review payroll policies and procedures over retaining approvals over employee’s salary. Views of Responsible Officials: Management is in agreement.
Finding 2023-002: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Section 223(f)/207) Statement of Condition: Internal control processes over financial reporting did not ensure that all transactions were properly recorded. Criteria: The HUD Handbook 4370.2, Chapter 2 requires the books and accounts to be complete and accurate. Additionally, 2 CFR Part 200 Section 200.302 Financial Management states that the financial management system of each non-federal entity must provide accurate, current, and complete disclosure of the financial results of each Federal award in accordance with the reporting requirements. Additionally, 2 CFR Part 200 Section 200.303(a), Internal Controls, requires that non-federal entities must establish and maintain effective internal controls over the federal award that provides reasonable assurance that the non-federal entity is managing the award in compliance with federal statutes, regulations and the terms and conditions. Effect: Noncompliance with HUD and Uniform Guidance regulations. Cause: Management oversight. Context: A review of journal entries made during the year revealed journal entries made in the incorrect period and erroneous journal entries. Additionally, the review process of the Corporation's financial information did not discover these errors. Recommendation: We recommend management review/enhance its accounting and internal control procedures to ensure that all key accounts are reconciled and reviewed with supporting evidence of such review. Questioned Costs: N/A Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding and will review the accounting and financial procedures, system of internal controls and policies.
Finding 2023-001: Submissions of Data Collection Forms Federal Programs: All Criteria: As stated in 2 CFR §200.303, the non-Federal entity (i.e. the Organization) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.512(a)(1) the audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Condition: The Data Collection Forms for each of the audits for the years ended December 31, 2021, 2022 and 2023 were not filed timely in accordance with the requirements under Uniform Guidance. Cause: The Organization did not have adequate controls in place to allow the Data Collection Form to be filed timely. Effect or Potential Effect: Delinquent data collection forms may result in action by funders such as 1) draw-down restrictions, 2) reimbursable draw-down restrictions, 3) withholding a percentage of Federal funds, 4) suspending Federal funds, or 5) termination of the award. Questioned Costs: None. Context: The past three years of Data Collection Forms have not been filed timely. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Organization establish an internal control procedure to ensure the required data collection form, along with the reporting package is filed timely.
Finding 2023-001: Submissions of Data Collection Forms Federal Programs: All Criteria: As stated in 2 CFR §200.303, the non-Federal entity (i.e. the Organization) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.512(a)(1) the audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Condition: The Data Collection Forms for each of the audits for the years ended December 31, 2021, 2022 and 2023 were not filed timely in accordance with the requirements under Uniform Guidance. Cause: The Organization did not have adequate controls in place to allow the Data Collection Form to be filed timely. Effect or Potential Effect: Delinquent data collection forms may result in action by funders such as 1) draw-down restrictions, 2) reimbursable draw-down restrictions, 3) withholding a percentage of Federal funds, 4) suspending Federal funds, or 5) termination of the award. Questioned Costs: None. Context: The past three years of Data Collection Forms have not been filed timely. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Organization establish an internal control procedure to ensure the required data collection form, along with the reporting package is filed timely.
Finding 2023-001: Submissions of Data Collection Forms Federal Programs: All Criteria: As stated in 2 CFR §200.303, the non-Federal entity (i.e. the Organization) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.512(a)(1) the audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Condition: The Data Collection Forms for each of the audits for the years ended December 31, 2021, 2022 and 2023 were not filed timely in accordance with the requirements under Uniform Guidance. Cause: The Organization did not have adequate controls in place to allow the Data Collection Form to be filed timely. Effect or Potential Effect: Delinquent data collection forms may result in action by funders such as 1) draw-down restrictions, 2) reimbursable draw-down restrictions, 3) withholding a percentage of Federal funds, 4) suspending Federal funds, or 5) termination of the award. Questioned Costs: None. Context: The past three years of Data Collection Forms have not been filed timely. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Organization establish an internal control procedure to ensure the required data collection form, along with the reporting package is filed timely.
2023-006 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Prior Year Finding Number: N/A Year of Finding Origination: 2023 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 controls 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. Administrative program costs for Medical Assistance Program are submitted to the Minnesota Department of Human Services (DHS) through the DHS Income Maintenance (DHS-2550) report and the Social Service Fund (DHS-2556) report on a quarterly basis. DHS provides reporting instructions including information regarding eligible and ineligible costs. Condition: The following exceptions were noted in the sample of 40 expenditures tested for activities allowed or unallowed and allowable costs/cost principles: • Two claims were included in the DHS-2550 reports as eligible expenditures but were not eligible for federal reimbursement. • For three timesheets tested, the payroll costs were allocated on an incorrect full-time equivalent (FTE) split on the DHS-2550 and DHS-2556 reports as the FTE split was updated during 2023 for non-payroll costs but not for payroll costs. • Two timesheets were included in the DHS-2556 reports for Social Service Time Study Random Moment Time Study (SSTS RMS) Participants Payroll Expense rather than Non SSTS RMS Participants Payroll Expense. • One timesheet was included in the DHS-2556 report as an eligible payroll expense but was not eligible for federal reimbursement. • One claim was included in the DHS-2556 report as an eligible expenditure but was not eligible for federal reimbursement. Questioned Costs: $343,656. Context: DHS relies on accurate identification and reporting of program costs to ensure grant funds paid to the County are for allowable federal program activities/costs and provide detailed information necessary for maintaining proper oversight over federal programs. DHS determines the rate of reimbursement for costs reported; the amount of questioned costs represents actual costs and does not reflect the amount reimbursed to the County for this grant. The sample sizes were based on the guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Errors in the identification and reporting of costs on the quarterly reports can impair the ability of DHS to provide required oversight over federal programs and result in the County receiving either more or less federal funds than justified based on the actual underlying activity. Cause: The County’s controls over the identification of allowable activities and costs, preparation of the quarterly reports, and maintenance of payroll allocations in the accounting system were not sufficient to identify these errors. Recommendation: We recommend the County implement controls to ensure activities allowed and allowable costs are appropriately identified and accurately reported to DHS in accordance with federal program guidance and DHS instructions. We also recommend the County correct and resubmit reports submitted with unallowable activities or costs, costs allocated incorrectly, or activity reported incorrectly. View of Responsible Official: Acknowledge
2023-007 Social Service Fund Reporting (DHS-2556) Prior Year Finding Number: N/A Year of Finding Origination: 2023 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Material Weakness and Modified Opinion Federal Agency: U.S. Department of Heath 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. Administrative program costs for Medical Assistance Program are submitted to the Minnesota Department of Human Services (DHS) through the Social Service Fund (DHS-2556) report on a quarterly basis. DHS provides reporting instructions including information regarding eligible and ineligible costs. Condition: The DHS-2556 second and fourth quarter reports overstated “Other Expenses” by $104,180 for expenses not related to the Social Service program and, therefore, not eligible to be included in the reported balances. Questioned Costs: $104,180. Context: DHS relies on accurate identification and reporting of program costs to ensure grant funds paid to the County are for allowable federal program activities/costs and provide detailed information necessary for maintaining proper oversight over federal programs. DHS determines the rate of reimbursement for costs reported; the amount of questioned costs represents actual costs and does not reflect the amount reimbursed to the County for this grant. The sample sizes were based on the guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Errors in the reporting of costs on the quarterly reports can impair the ability of DHS to provide required oversight over federal programs and result in the County receiving either more or less federal funds than justified based on the actual underlying activity. Cause: The County’s controls over preparation of the quarterly reports were not sufficient to identify the reporting errors. Recommendation: We recommend the County implement controls to ensure accurate reporting to DHS in accordance with federal program guidance and DHS instructions. We also recommend the County correct and resubmit incorrect reports. View of Responsible Official: Acknowledge
Federal Agency: U.S. Department of Health and Human Services Federal Program: Medical Assistance Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2305MN5MAP -2023, 2305MN5ADM -2023 Compliance Requirement Affected: Eligibility Award Period: Year Ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Controls over Compliance Criteria or Specific Requirement: 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 County did not have adequate internal controls over the casefiles. Questioned Costs: None Context: The County did not have anyone internally reviewing the casefiles. Cause: Limited number of personnel. Effect: The County could be reporting inaccurate information effecting the status of eligibility. Repeat Finding: No Recommendation: We recommend the County designate qualified personnel responsible for conducting casefile reviews. The reviews should be performed on predetermined frequencies and documented. Formal procedures should be documented to ensure consistency and effectiveness of the quality review process. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-002: Disbursement Approval and Documentation Information on the Federal Program: 93.471 Criteria or Specific Requirement: CFR 200.303 specifies that the Organization must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Organization has certain items which are set to auto-pay (i.e. accounting services, insurance and retirement payments), and as a result no payment authorization is available. In addition we noted several instances where the contract was meant to serve as payment authorization (there was no specific authorization of disbursement). Cause: The Organization has not required a separate authorization for payment of certain items that are either on auto-pay or are paid based on contracts. The Organization has a payables processing system that could maintain approval and payment documentation as well as the associated supporting documents, but is not using it to process some payments.Effect or Potential Effect: It is critical to maintain payment authorization support to avoid unauthorized payments, questioned costs and other potential issues. Questioned Costs: None noted. Context: Although none of the items noted without authorization were charged to the major program, our testwork consisted of statistical sampling as well as substantive testwork over various samples of expenditures, and were determined to be representative of the population for the fiscal year under audit. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: We recommend that the Organization ensure that documentation of authorization is documented and available.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.303(a) which requires that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.403 which states except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also § 200.306(b). (g) Be adequately documented. See also §§ 200.300 through 200.309 of this part. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3). State ex rel. McClure v. Hagerman, 155 Ohio St. 320 (1951) provides that expenditures made by a governmental unit should serve a public purpose. Typically, the determination of what constitutes a “proper public purpose” rests with the judgment of the governmental entity, unless such determination is arbitrary or unreasonable. Even if a purchase is reasonable, Ohio Attorney General Opinion 82-006 indicates that it must be memorialized by a duly enacted ordinance or resolution and may have a prospective effect only. Auditor of State Bulletin 2003-005 Expenditure of Public Funds/Proper “Public Purpose” states, in part, the Auditor of State’s Office will only question expenditures where the legislative determination of a public purpose is manifestly arbitrary and incorrect. The Lima-Allen County Regional Planning Commission, administrator of the Community Housing Impact and Preservation Program - CHIP (#B-C-21-1AB-1) for Allen County, incurred a charge of $4,386 for Admin January 2023 charges on invoice #106558 dated February 7, 2023 from the Great Lakes Community Action Partnership. On July 6, 2023, check number 7330652 was issued by Allen County which included payment of $4,386 on invoice number 106558. On August 3, 2023, check number 7332670 was issued by Allen County which included payment of $4,386 on invoice number 106558 which was approved by Tara Bales, Executive Director of the Lima-Allen County Regional Planning Commission. As a result, possibly due to the failure of an existing control or procedure, invoice number 106558 was paid twice resulting an overpayment of $4,386. On October 2, 2024, the Great Lakes Community Action Partnership refunded the overpayment with check number 20765 in the amount of $4,386. This refund was recorded in the Community Development Grant Fund (2414). The Lima-Allen County Regional Planning Commission should implement an additional control(s) and/or procedure(s) to prevent the duplicate payment of invoices.
Federal Agency: Department of Health and Human Services Federal Program Title: Refugee and Entrant Assistance Discretionary Grants Assistance Listing Number: 93.576 Pass-Through Agency: Lutheran Immigration & Refugee Services Pass-Through Number(s): 90ZM003101, 90ZM003102, 90ZR007401, 90ZR007402, 90Z1014104, 90Z0107301, 90RP0 124-02, 90RP0-124-03 & 90RP0 124-01 Award Period: September 30, 2022 – September 29, 2024 Type of Finding: Material Weaknesses in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award Section 200.303 requires entities to establish and maintain effective internal controls over Federal Awards. Condition: During our testing we noted internal controls over drawdown requests were not always properly followed. Questioned Costs: None Context: 6 of 13 drawdown requests in our sample were missing approvals. Cause: LSI has a limited number of individuals in the finance department and has experienced significant turnover in the finance department. Effect: The lack of internal controls over cash management provides an opportunity for noncompliance. Repeat Finding: Yes – see 2022-006. Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all drawdown requests. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: Department of Health and Human Services Federal Program Title: Refugee and Entrant Assistance Discretionary Grants Assistance Listing Number: 93.576 Pass-Through Agency: Lutheran Immigration & Refugee Services Pass-Through Number(s): 90ZM003101, 90ZM003102, 90ZR007401, 90ZR007402, 90Z1014104, 90Z0107301, 90RP0 124-02, 90RP0-124-03 & 90RP0 124-01 Award Period: September 30, 2022 – September 29, 2024 Type of Finding: Material Weaknesses in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award Section 200.303 requires entities to establish and maintain effective internal controls over Federal Awards. Condition: During our testing we noted internal controls over drawdown requests were not always properly followed. Questioned Costs: None Context: 6 of 13 drawdown requests in our sample were missing approvals. Cause: LSI has a limited number of individuals in the finance department and has experienced significant turnover in the finance department. Effect: The lack of internal controls over cash management provides an opportunity for noncompliance. Repeat Finding: Yes – see 2022-006. Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all drawdown requests. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: Department of Health and Human Services Federal Program Title: Refugee and Entrant Assistance Discretionary Grants Assistance Listing Number: 93.576 Pass-Through Agency: Lutheran Immigration & Refugee Services Pass-Through Number(s): 90ZM003101, 90ZM003102, 90ZR007401, 90ZR007402, 90Z1014104, 90Z0107301, 90RP0 124-02, 90RP0-124-03 & 90RP0 124-01 Award Period: September 30, 2022 – September 29, 2024 Type of Finding: Material Weaknesses in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award Section 200.303 requires entities to establish and maintain effective internal controls over Federal Awards. Condition: During our testing we noted internal controls over drawdown requests were not always properly followed. Questioned Costs: None Context: 6 of 13 drawdown requests in our sample were missing approvals. Cause: LSI has a limited number of individuals in the finance department and has experienced significant turnover in the finance department. Effect: The lack of internal controls over cash management provides an opportunity for noncompliance. Repeat Finding: Yes – see 2022-006. Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all drawdown requests. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: Department of Health and Human Services Federal Program Title: Refugee and Entrant Assistance Discretionary Grants Assistance Listing Number: 93.576 Pass-Through Agency: Lutheran Immigration & Refugee Services Pass-Through Number(s): 90ZM003101, 90ZM003102, 90ZR007401, 90ZR007402, 90Z1014104, 90Z0107301, 90RP0 124-02, 90RP0-124-03 & 90RP0 124-01 Award Period: September 30, 2022 – September 29, 2024 Type of Finding: Material Weaknesses in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award Section 200.303 requires entities to establish and maintain effective internal controls over Federal Awards. Condition: During our testing we noted internal controls over drawdown requests were not always properly followed. Questioned Costs: None Context: 6 of 13 drawdown requests in our sample were missing approvals. Cause: LSI has a limited number of individuals in the finance department and has experienced significant turnover in the finance department. Effect: The lack of internal controls over cash management provides an opportunity for noncompliance. Repeat Finding: Yes – see 2022-006. Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all drawdown requests. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: Department of Health and Human Services Federal Program Title: Refugee and Entrant Assistance Discretionary Grants Assistance Listing Number: 93.576 Pass-Through Agency: Lutheran Immigration & Refugee Services Pass-Through Number(s): 90ZM003101, 90ZM003102, 90ZR007401, 90ZR007402, 90Z1014104, 90Z0107301, 90RP0 124-02, 90RP0-124-03 & 90RP0 124-01 Award Period: September 30, 2022 – September 29, 2024 Type of Finding: Material Weaknesses in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award Section 200.303 requires entities to establish and maintain effective internal controls over Federal Awards. Condition: During our testing we noted internal controls over drawdown requests were not always properly followed. Questioned Costs: None Context: 6 of 13 drawdown requests in our sample were missing approvals. Cause: LSI has a limited number of individuals in the finance department and has experienced significant turnover in the finance department. Effect: The lack of internal controls over cash management provides an opportunity for noncompliance. Repeat Finding: Yes – see 2022-006. Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all drawdown requests. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: Department of Health and Human Services Federal Program Title: Adoption Assistance Assistance Listing Number: 93.659 Pass-Through Agency: Iowa Department of Human Services and Four Oaks Family & Children Pass-Through Number(s): ACFS 18-007 & FWBP-CPS-24-002 Award Period: July 1, 2022 – June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award Section 200.303 requires entities to establish and maintain effective internal controls over Federal Awards. Condition: During our testing we noted internal controls over drawdown requests were not always properly followed. Questioned Costs: None Context: 4 of 6 drawdown requests in our sample were missing approvals. Cause: LSI has a limited number of individuals in the finance department and has experienced significant turnover in the finance department. Effect: The lack of internal controls over cash management provides an opportunity for noncompliance. Repeat Finding: Yes – see 2022-004, 2022-005, 2022-006 Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all drawdown requests. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: Department of Health and Human Services Federal Program Title: Adoption Assistance Assistance Listing Number: 93.659 Pass-Through Agency: Iowa Department of Human Services and Four Oaks Family & Children Pass-Through Number(s): ACFS 18-007 & FWBP-CPS-24-002 Award Period: July 1, 2022 – June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award Section 200.303 requires entities to establish and maintain effective internal controls over Federal Awards. Condition: During our testing we noted internal controls over drawdown requests were not always properly followed. Questioned Costs: None Context: 4 of 6 drawdown requests in our sample were missing approvals. Cause: LSI has a limited number of individuals in the finance department and has experienced significant turnover in the finance department. Effect: The lack of internal controls over cash management provides an opportunity for noncompliance. Repeat Finding: Yes – see 2022-004, 2022-005, 2022-006 Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all drawdown requests. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: Department of Health and Human Services Federal Program Title: Refugee and Entrant Assistance Discretionary Grants Assistance Listing Number: 93.576 Pass-Through Agency: Lutheran Immigration & Refugee Services Pass-Through Number(s): 90ZM003101, 90ZM003102, 90ZR007401, 90ZR007402, 90Z1014104, 90Z0107301, 90RP0 124-02, 90RP0-124-03 & 90RP0 124-01 Award Period: September 30, 2022 – September 29, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award Section 200.303 requires entities to establish and maintain effective internal controls over Federal Awards. Condition: During our testing we noted internal controls over reports were not always properly followed. Questioned Costs: None Context: 1 of 7 reports in our sample were missing approvals. Cause: LSI has a limited number of individuals in the finance department and has experienced significant turnover in the finance department. Effect: The lack of internal controls over reporting provides an opportunity for noncompliance. Repeat Finding: Not a repeat finding. Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all reports. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: Department of Health and Human Services Federal Program Title: Refugee and Entrant Assistance Discretionary Grants Assistance Listing Number: 93.576 Pass-Through Agency: Lutheran Immigration & Refugee Services Pass-Through Number(s): 90ZM003101, 90ZM003102, 90ZR007401, 90ZR007402, 90Z1014104, 90Z0107301, 90RP0 124-02, 90RP0-124-03 & 90RP0 124-01 Award Period: September 30, 2022 – September 29, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award Section 200.303 requires entities to establish and maintain effective internal controls over Federal Awards. Condition: During our testing we noted internal controls over reports were not always properly followed. Questioned Costs: None Context: 1 of 7 reports in our sample were missing approvals. Cause: LSI has a limited number of individuals in the finance department and has experienced significant turnover in the finance department. Effect: The lack of internal controls over reporting provides an opportunity for noncompliance. Repeat Finding: Not a repeat finding. Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all reports. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: Department of Health and Human Services Federal Program Title: Refugee and Entrant Assistance Discretionary Grants Assistance Listing Number: 93.576 Pass-Through Agency: Lutheran Immigration & Refugee Services Pass-Through Number(s): 90ZM003101, 90ZM003102, 90ZR007401, 90ZR007402, 90Z1014104, 90Z0107301, 90RP0 124-02, 90RP0-124-03 & 90RP0 124-01 Award Period: September 30, 2022 – September 29, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award Section 200.303 requires entities to establish and maintain effective internal controls over Federal Awards. Condition: During our testing we noted internal controls over reports were not always properly followed. Questioned Costs: None Context: 1 of 7 reports in our sample were missing approvals. Cause: LSI has a limited number of individuals in the finance department and has experienced significant turnover in the finance department. Effect: The lack of internal controls over reporting provides an opportunity for noncompliance. Repeat Finding: Not a repeat finding. Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all reports. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: Department of Health and Human Services Federal Program Title: Refugee and Entrant Assistance Discretionary Grants Assistance Listing Number: 93.576 Pass-Through Agency: Lutheran Immigration & Refugee Services Pass-Through Number(s): 90ZM003101, 90ZM003102, 90ZR007401, 90ZR007402, 90Z1014104, 90Z0107301, 90RP0 124-02, 90RP0-124-03 & 90RP0 124-01 Award Period: September 30, 2022 – September 29, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award Section 200.303 requires entities to establish and maintain effective internal controls over Federal Awards. Condition: During our testing we noted internal controls over reports were not always properly followed. Questioned Costs: None Context: 1 of 7 reports in our sample were missing approvals. Cause: LSI has a limited number of individuals in the finance department and has experienced significant turnover in the finance department. Effect: The lack of internal controls over reporting provides an opportunity for noncompliance. Repeat Finding: Not a repeat finding. Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all reports. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: Department of Health and Human Services Federal Program Title: Refugee and Entrant Assistance Discretionary Grants Assistance Listing Number: 93.576 Pass-Through Agency: Lutheran Immigration & Refugee Services Pass-Through Number(s): 90ZM003101, 90ZM003102, 90ZR007401, 90ZR007402, 90Z1014104, 90Z0107301, 90RP0 124-02, 90RP0-124-03 & 90RP0 124-01 Award Period: September 30, 2022 – September 29, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award Section 200.303 requires entities to establish and maintain effective internal controls over Federal Awards. Condition: During our testing we noted internal controls over reports were not always properly followed. Questioned Costs: None Context: 1 of 7 reports in our sample were missing approvals. Cause: LSI has a limited number of individuals in the finance department and has experienced significant turnover in the finance department. Effect: The lack of internal controls over reporting provides an opportunity for noncompliance. Repeat Finding: Not a repeat finding. Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all reports. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: Department of Health and Human Services Federal Program Title: Refugee Admissions Program Assistance Listing Number: 93.567 Pass-Through Agency: Refugee and Entrant Assistance Voluntary Agency Program Pass-Through Number(s): 2302MDRVMG Award Period: October 1, 2022 – September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award Section 200.303 requires entities to establish and maintain effective internal controls over Federal Awards. Condition: During our testing we noted internal controls over disbursements were not always properly followed. Questioned Costs: None Context: 2 of 19 payroll selections in our sample did not have timesheet approvals. Cause: LSI has a limited number of individuals in the finance department and has experienced significant turnover in the finance department. Effect: The auditor noted no instances of noncompliance with the allowability of costs or support for costs; the lack of internal controls over disbursements provides an opportunity for noncompliance. Repeat Finding: Yes – see 2022-003 Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all disbursements. Views of Responsible Officials: There is no disagreement with the audit finding.
FINDING 2023-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, and 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): PO 20011717 Pass-Through Entity: Indiana State Department of Health Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context The County Department of Health, a department within the County, was awarded the Health Issues and Challenges grant through the Indiana State Department of Health financed through the American Rescue Plan Act for the purpose of funding programs that focus on the improvement of chronic disease, specifically, elevated blood lead level reduction. The Health Issues and Challenges grant is a reimbursable grant, whereby the County received reimbursement on a per-case basis at a stated rate for Case Management and Environmental Investigation activities performed. The County Department of Health received federal receipts related to the grant in the amount of $130,479 during 2023. As part of sound management of the federal award, the County Department of Health was responsible for implementing a system of internal controls that would ensure compliance with the applicable requirements. The County Department of Health did not properly design or implement such a system. Receipts of the program were adequately identified through the use of an account number within the County Health Fund (285) in the County's ledger (ledger) which was unique to the Health Issues and Challenges grant receipts. However, the ledger did not adequately identify the expenditures of the grant program within the County Health Fund. Through inquiry with the County Department of Health employees and review of unit-prepared support of grant expenditures, we determined expenditures were made with grant funds during the audit period; however, we were unable to distinguish between the expenditures of the Health Issues and Challenges grant and all other activities of the County Department of Health in the County Health fund. Due to the lack of separate identification of expenditures in the financial records, we were not able to establish a population from which to audit the Health Issues and Challenges grant for compliance with the following compliance requirements of the program: Activities Allowed or Unallowed Allowable Costs/Cost Principles Period of Performance Procurement and Suspension and Debarment As such, the full award amount of $130,479, as reported on the Schedule of Expenditures of Federal Awards, was determined to be questioned costs. 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 200.300(b) states in part: "The non-Federal entity is responsible for complying with all requirements of the Federal award. . . ." 2 CFR 200.302 states in part: "(a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. . . . (b) The financial management system of each non-Federal entity must provide for the following . . . (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number and year, name of the Federal agency, and name of the pass-through entity, if any. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. . . ." Cause The County Department of Health was unable to differentiate expenditures made from federal and non-federal funds within its ledger for the Heath Issues and Challenges grant. Effect Without the proper implementation of an effectively designed system of internal controls, a population of expenditures associated with the Health Issues and Challenges grant could not be determined. As such, the County Department of Health cannot ensure nor can we determine that expenditures of the grant were not unallowable, within the proper period, and adhered to established practices and policies. Questioned Costs We identified $130,479 in known questioned costs as noted in the Condition and Context. Recommendation We recommended that management of the County Department of Health establish a system of internal controls to ensure that grant award funds are adequately accounted for and tracked in such a manner as to determine the activity, receipts, and disbursements associated with the grant. 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: 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): PO 20011717 Pass-Through Entity: Indiana State Department of Health Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context The County Department of Health, a department within the County, was awarded the Health Issues and Challenges grant through the Indiana State Department of Health financed through the American Rescue Plan Act (ARPA) for the purposes of funding programs that focus on the improvement of chronic disease, specifically, elevated blood lead level reduction. As part of sound management of the federal award, the County Department of Health was responsible for implementing a system of internal controls that would ensure compliance with the applicable requirements. The County Department of Health did not properly design or implement such a system. The County Department of Health was required to submit data through the online portal, National Electronic Disease Surveillance System (NEDSS) Base System (NBS), monthly beginning in October 2022. The submitted data included program specific metrics relating to patient case management of certified Elevated Blood Lead Levels (EBLLs). The County Department of Health was also required to ensure environmental investigation activities completed, including risk assessments and environmental inspections, were documented in the Indiana I-LEAD database monthly by a licensed Lead Risk Assessor. Environmental investigation activities performed by the County Department of Health were documented in the Indiana I-LEAD database by a licensed Lead Risk Assessor who was an employee of the County Department of Health. Similarly, case management activities performed were documented in the NEDSS Base System (NBS). Once activities were documented in the Indiana I-LEAD database and NBS systems, the activities were further documented in a spreadsheet by the Lead Risk Assessor (for I-LEAD activities) and the Case Management Coordinator (for NBS activities). The spreadsheet was reviewed by the Director of the Environmental Services Division and the Finance Director monthly. The Finance Director then used the spreadsheet to prepare the monthly reimbursement requests and sent the monthly reimbursement requests to the Indiana State Department of Health. We determined through inquiry with the Director of the Environmental Services Division and the Finance Director that while there was a review of the monthly spreadsheet, there was not a second review of the spreadsheet back to the activities reported in the Indiana I-LEAD database and NBS for accuracy. Additionally, the Finance Director prepared and submitted the reimbursement requests to the State without a second review or oversight process in place to prevent, or detect and correct, errors prior to submission. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal 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, which would include segregation of key functions, was not designed by management of the County Department of Health to ensure the state was provided with complete and accurate information related to the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds award. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect management's 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 design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County Department of Health design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place to ensure reports are 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 - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY 2023 Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context Recipients of COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) awards are required to submit quarterly or annually Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon 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. Counties with a population that exceeds 250,000 residents are further required to submit annually a Recovery Plan Performance Report (RPPR). The RPPR provides the public and the Treasury with both retrospective and prospective information on the projects that recipients are undertaking or planning to undertake with program funding and how they are planning to ensure program outcomes are achieved in an effective, efficient, and equitable manner. The County was classified as a metropolitan county with a population that exceeds 250,000 residents. As such, quarterly P&E reports were to cover one calendar quarter and were to be submitted to the Treasury by the last day of the month following the end of the period covered. The annual RPPR was to be submitted to the Treasury by July 31, 2023. An employee of the Board of County Commissioners prepared and submitted the four required quarterly P&E reports during the audit period; however, there was no review or oversight process in place to prevent, or detect and correct, errors. Additionally, an employee of the Board of County Commissioners submitted the required annual RPPR during the audit period, which was compiled by a contracted vendor on the County's behalf. The vendor worked with the employee to get the necessary information to complete the report. Once complete, the report was provided to the employee, who then submitted the report without a review or oversight process in place to prevent, or detect and correct, errors. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal 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, which would include segregation of duties, over SLFRF reporting was not designed by the Board of County Commissioners in order to prevent, detect or correct, material noncompliance. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect management's 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 design or implementation of the components of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Board of County Commissioners design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 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 Listing Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY 2023 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context The County received a total COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) allocation of $73,674,384 and chose to calculate its own revenue loss allowance, which totaled $35,932,557, to use for government services. Some SLFRF program funds expended in 2023 were expended under the revenue loss eligible use category. Additional program funds expended in 2023 were expended under the other eligible use categories. Procurement 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 non-federal 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 $10,000 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. For funds expended under the revenue loss eligible use category, the above listed procurement requirements do not apply. During the audit period, the County had four vendors with purchases over the $10,000 micropurchase threshold which were expended under an eligible use category other than revenue loss and, as such, were considered small purchase procurements. The County did not provide competitive price quotations for the small purchase procurements for three of the four vendors, which totaled $257,038. Suspension and Debarment Prior to entering into subawards and covered transactions with 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, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. During the engagement, an employee of the Board of County Commissioners stated that verification was completed by checking the Excluded Parties List System when covered transactions were entered into by the County to verify that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. Six covered transactions, totaling $3,952,203, were paid from SLFRF funds to six different vendors for goods or services that equaled or exceeded $25,000 during the audit period. Three of the six covered transactions were selected for testing. For all three transactions tested, documentation was not provided that the vendor's suspension and debarment status was verified. 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." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases — (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . . Cause The County was unable to provide documentation to demonstrate it had properly procured services. In addition, the County was unable to provide documentation to demonstrate it had checked the Excluded Parties List System, per the County's procedures, to ensure vendors were not suspended or debarred prior to entering into covered transactions that exceeded $25,000. Effect Without the proper implementation of an effectively designed system of internal controls, the County cannot demonstrate it obtained an adequate number of price or rate quotations prior to selecting a vendor. Therefore, the County could have overpaid for the services obtained. Furthermore, without the proper implementation of an effectively designed system of internal controls, the County cannot ensure the vendors paid with federal funds are eligible to participate in federal programs. Any program funds the County used to pay vendors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Board of County Commissioners strengthen the County's system of internal controls to ensure that an adequate number of price or rate quotations are obtained for small purchase procurements. Additionally, we recommended policies and procedures be strengthened to ensure appropriate supporting documentation for federal programs is retained. Lastly, we recommended that the Board of County Commissioners strengthen the County's 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 2023-002 – Internal Control Deficiency and Noncompliance over Activities Allowed/Allowable Costs Principles, Period of Performance Identification of the federal program: Federal grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the ‘Internal Control Integrated Framework,’ issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” In order for expenditures to be allowable under federal awards, 2 CFR 200.403(a) provides that costs must be necessary and reasonable for the performance of the federal award and be allocable thereto under the cost principles. 2 CFR 200.403(g) further provides that costs must be adequately documented. Condition: Management did not have adequately designed internal controls throughout the year over expenses charged to the federal program. Management also did not consistently retain evidence to support the existence of certain expenditures and thus the expenses were not adequately documented. Section III – Federal Award Findings and Questioned Costs (continued) Cause: Due to the timing of identifying the internal control finding during the 2022 audit, management was not able to timely implement effective internal controls for the entire period under audit for 2023. For certain expenditures, management did not adequately retain invoice or receipt support for non-payroll direct expenditures. Effect or potential effect: Ineffective internal controls could result in expenses being charged to the federal program that are not allowed or are outside the period of performance. Questioned costs: $610. Questioned costs were calculated as the costs without support for the expenditure. Context: Prior to October 15, 2023, payroll controls were designed where the Executive Director reviewed time sheets of the employees working on the program; however, no one reviewed the time submitted by the Executive Director, and if the Executive Director was not available to review the employees’ time sheets, a third-party payroll servicer approved the time. The third-party servicer did not have firsthand knowledge of the activities of each employee. Because the internal controls prior to October 15, 2023, were not designed effectively, we did not test controls over payroll expenditures as they were not in place throughout the audit period. For direct expenses, internal requisitions are to be approved by either the Executive Director or the Assistant Program Director if under $5,000 and by the Executive Director if over $5,000 prior to AdviseWell, Inc. entering into a transaction. Because the internal controls were not implemented timely, we did not test controls surrounding direct expenses. We selected 40 nonpayroll expenditures totaling $13,590 from total nonpayroll expenditures of $590,516 to test allowability, noting that for three selections totaling $610, documentation was not retained to evidence the existence and allowability of the expenditure. For indirect expenses and fringe benefits, the Executive Director calculates the amount and requests reimbursement from the federal program. There was no independent review of the Executive Director’s calculations prior to submitting the request for reimbursement throughout the period under audit. Management asserts that it has internal controls in place to ensure that allowable expenditures are charged to the federal programs within the period of performance. Management did not retain documentation to evidence the internal controls over its review of expenditures to ensure they were within the period of performance. Because evidence of the controls was not retained for the period of performance throughout the entire audit period, we did not test internal controls. Identification as a repeat finding, if applicable: This is a repeat finding – Finding 2022-001. Recommendation: AdviseWell, Inc. should develop and implement effective internal controls to ensure expenses charged to the federal program are appropriately reviewed and approved by an individual knowledgeable of the program requirements, reviewed prior to entering into the expenditure, and charged within the period of performance. Management should maintain effective segregation of duties. Management should retain invoice or receipt support for all expenditures. View of responsible officials: Management agrees with the finding. Internal controls were enhanced in October 2023 to begin retaining documentation to evidence the controls. Additionally, management will implement internal controls surrounding retaining evidence of expenditures.
Finding 2023-005 – Internal Control Deficiency and Noncompliance Over Procurement Identification of the federal program: Federal grantor: United States Department of Health and Human Services Assistance listing no.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the ‘Internal Control Integrated Framework,’ issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318(i) – General procurement standards states: “The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.320 – Methods of procurement to be followed states: ”The non-Federal entity must have and use documented procurements 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) (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; (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines appropriate: (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded.” Title 2, Subtitle A, Chapter II, Part 200, Subpart C, 200.214 – Suspension and debarment states: “Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: AdviseWell, Inc. did not have internal controls in place throughout the audit period to sufficiently document the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price or sole source justification if warranted. Additionally, management did not have evidence of internal controls being in place throughout the audit period to document that vendors were not suspended or debarred prior to entering into a procurement transaction. AdviseWell, Inc. did not have or use documented procurements procedures throughout the audit period. Cause: Management did not have effective internal controls in place throughout the audit period over the compliance requirement as stated in the criteria section above. Effect or potential effect: Procurements were not supported by effective internal controls and could potentially include unreasonable prices or missing documentation to support the procurements made. If suspension and debarment searches are not conducted, the organization could contract with vendors that are suspended or debarred. Lack of written policies and procedures is out of compliance with the federal requirements and could lead to disallowed procurements. Questioned costs: $80,082. Questioned costs were determined based on the expenditures of the procurements. Context: For five procurements selected for testing totaling $80,082 out of a total population of procurements of $145,646, required documentation was not available supporting the history of the procurement, including rationale for sole source selection. As the written procurement policy was not in place throughout the year and/or documentation of debarment searches on vendors was not maintained throughout the year, we were unable to test these controls. Identification as a repeat finding, if applicable: This is a repeat finding – Finding 2022-004. Recommendation: AdviseWell, Inc. should develop and implement effective internal controls throughout the audit period to ensure procurements are in accordance with the federal guidelines. AdviseWell, Inc. should search for suspension and debarment prior to entering into a procurement transaction and retain documentation that the search was conducted prior to entering into the transaction. AdviseWell, Inc. should periodically search recurring vendors for suspension and debarment and retain documentation to support that the search was conducted. View of responsible officials: Management agrees with the finding. A procurement policy was established in October 2023 in accordance with the federal requirements, and documentation for each procurement was retained subsequent to October 2023. Management began retaining documentation that searches were conducted for vendors for suspension and debarment prior to entering into the procurement and on a periodic basis for recurring vendors.
2 CFR 200.303 requires that organizations receiving federal awards must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Formal controls were not established or documented surrounding the following compliance requirements specified for this grant under 2 CFR Part 200, Appendix XI: Activities allowed or unallowed and allowable cost principles – lack of documented, timely review and approval of expenditures for three of eight transactions selected for testing; specifically relating to payroll expenditures. Suspension and Debarment – no established internal control policies to verify that vendors selected for use were not suspended or debarred from use for expenditures of federal awards. Subrecipient monitoring – no established internal control policies surrounding monitoring of subrecipients for compliance with principles established under 2 CFR Part 200, Appendix XI. The Foundation and its affiliates have not established internal control policies to ensure compliance with principles established under the Uniform Guidance. Lack of internal controls could result in instances of noncompliance with federal grant requirements, which could lead to loss of future funding or requests for repayment of federal awards previously distributed by federal agencies. Not applicable. This is not a repeat finding. The Foundation and its affiliates should establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework" issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Management's response is reported in "Corrective Action Plan" at the end of this report.
2 CFR 200.303 requires that organizations receiving federal awards must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Formal controls were not established or documented surrounding the following compliance requirements specified for this grant under 2 CFR Part 200, Appendix XI: Activities allowed or unallowed and allowable cost principles – lack of documented, timely review and approval of expenditures for three of eight transactions selected for testing; specifically relating to payroll expenditures. Suspension and Debarment – no established internal control policies to verify that vendors selected for use were not suspended or debarred from use for expenditures of federal awards. Subrecipient monitoring – no established internal control policies surrounding monitoring of subrecipients for compliance with principles established under 2 CFR Part 200, Appendix XI. The Foundation and its affiliates have not established internal control policies to ensure compliance with principles established under the Uniform Guidance. Lack of internal controls could result in instances of noncompliance with federal grant requirements, which could lead to loss of future funding or requests for repayment of federal awards previously distributed by federal agencies. Not applicable. This is not a repeat finding. The Foundation and its affiliates should establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework" issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Management's response is reported in "Corrective Action Plan" at the end of this report.
2 CFR 200.303 requires that organizations receiving federal awards must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Formal controls were not established or documented surrounding the following compliance requirements specified for this grant under 2 CFR Part 200, Appendix XI: Activities allowed or unallowed and allowable cost principles – lack of documented, timely review and approval of expenditures for three of eight transactions selected for testing; specifically relating to payroll expenditures. Suspension and Debarment – no established internal control policies to verify that vendors selected for use were not suspended or debarred from use for expenditures of federal awards. Subrecipient monitoring – no established internal control policies surrounding monitoring of subrecipients for compliance with principles established under 2 CFR Part 200, Appendix XI. The Foundation and its affiliates have not established internal control policies to ensure compliance with principles established under the Uniform Guidance. Lack of internal controls could result in instances of noncompliance with federal grant requirements, which could lead to loss of future funding or requests for repayment of federal awards previously distributed by federal agencies. Not applicable. This is not a repeat finding. The Foundation and its affiliates should establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework" issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Management's response is reported in "Corrective Action Plan" at the end of this report.
2023-001 – ALN 14.850 – Public & Indian Housing – Allowable Costs Condition and Criteria: Loss of Internal Controls over Credit Card In a sample of Five (5) months of Credit Card statements and reconciliations, the following deficiencies were noted: 1 Month (January 2023) had an amount of $1,416.44 of transactions that were not supported 2 Month (February 2023) had an amount of $4,174.24 of transactions that were not supported. 3 Month (March 2023) had an amount of $1,501.68 of transactions that were not supported . 4 Month (August 2023) had an amount of $534.45 of transactions that were not supported . 5 Month (November 2023) had an amount of $476.38 of transactions that were not supported . 1 CFR § 200.303 states that (a) The PHA must establish and maintain effective internal controls over the federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with the cost principles under 2 CFR part 200, subpart E, costs must be necessary and reasonable for the performance of the Federal award, conform to any limitations or exclusions set forth in 2 CFR part 200, subpart E, and be adequately documented. Amount of Questioned Costs. None. Context: Of forty check disbursements tested, five of these disbursements were credit card payments. The Authority was unable to locate supporting backup documentation for some of the charges on all five of these credit card disbursements tested. Cause: The Authority's deficiencies in its credit card reconciliations stem from a lack of certain controls concerning HUD requirements and procedures. Effect: The Authority has not been in complete compliance with HUD requirements. The Authority could incur costs that are unallowable and that are not necessary or reasonable. These internal control deficiencies could result in a possibility that errors or irregularities relating to costs can exist and not be detected by the Authority’s internal controls. Auditor’s Recommendation: We recommend that the Authority’s management take the necessary steps to ensure that all disbursements are sufficiently documented and supported by adequate backup. We also recommend that the Authority implement controls to detect when check disbursements do not have adequate support in accordance with 2 CFR part 200, subpart E. Grantee Response: Current management acknowledges the finding and is following the auditor’s recommendations.
2023-005 Suspension and Debarment 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: SLFRP4411; 2021 Pass-Through Agency: N/A – Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction. Condition: For both covered transactions selected for testing, the County did not perform the verification for suspended or debarred vendors prior to entering into the covered transactions. Questioned Costs: None. Context: There were four covered transactions during the year. The County provided funds to entities which have operated for many years and were familiar to the County. In addition, neither of the vendors tested were listed as suspended or debarred on SAM.gov at the time of the audit. 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 prior to entering into a covered transaction may result in the County entering into a transaction with a vendor that is not authorized to provide goods and services under the grant. Cause: County staff were not aware of the requirement. Recommendation: We recommend the County maintain documentation to demonstrate that vendors were not debarred, suspended, or otherwise excluded from conducting business with the County; this documentation should be completed prior to entering into a covered transaction. View of Responsible Official: Acknowledge
Criteria or specific requirement: Per 2 CFR 200.331(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes, federal award identification, subrecipient name, subrecipient’s DUNS number, federal award identification number (FAIN), federal award date, subaward start and end date, amount of federal funds obligated, total amount of federal award, federal award project description, name of federal awarding agency, Assistance Listing (CFDA) number and name, identification of whether the award is R&D and indirect cost rate for federal award. Per 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 control should include procedures to ensure required information is communicated prior to the issuance of the subaward. Per 2 CFR 200.331(a)(1), pass-through entities must evaluate each subrecipient’s risk of noncompliance to determine the appropriate level of monitoring of the subrecipient. Per 2 CFR 200.332(d) through (f), pass-through entities must monitor the activities of the subrecipient, which includes reviewing financial reports required by the pass-through entity. Condition: During our testing, we noted subrecipients tested had required information omitted from the sub agreements to the subrecipients including Assistance Listing (CFDA) title and number, subrecipient’s DUNS number, Federal Award Identification Number (FAIN), identification of whether the award is research and development, and indirect cost rate for federal award. Subrecipients tested did not have evidence of the County’s evaluation of the risk of noncompliance by the subrecipients, nor was there evidence of monitoring of annual audits for the subrecipients. Internal checklists that aid in compliance were missing for certain subrecipients. Quarterly reports were also not submitted to the County by the subrecipients subsequent to funding. Questioned costs: None. Context: Five out of the five subrecipients did not include required information in subaward agreements issued to subrecipients and lacked evidence of both the evaluation of risk of noncompliance of the subrecipient and monitoring of annual audits for the subrecipients. One of the five subrecipients was missing an internal checklist that is signed by the County Manager. Five of the five subrecipients were provided the funding at the beginning of the grant award period and no required quarterly reports were submitted to the County subsequent to funding. Cause: Lack of sufficient controls in place to ensure that subrecipient agreements contain all required information and are monitored appropriately. Effect: Failure to communicate required information and to adequately monitor the subrecipients could result in subrecipients not properly administering the federal programs in accordance with federal regulations. Repeat Finding: Yes, repeat of prior year finding 2022-004. Recommendation: CLA recommends that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding and that appropriate monitoring is performed for each subrecipient. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR 200.331(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes, federal award identification, subrecipient name, subrecipient’s DUNS number, federal award identification number (FAIN), federal award date, subaward start and end date, amount of federal funds obligated, total amount of federal award, federal award project description, name of federal awarding agency, Assistance Listing (CFDA) number and name, identification of whether the award is R&D and indirect cost rate for federal award. Per 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 control should include procedures to ensure required information is communicated prior to the issuance of the subaward. Per 2 CFR 200.331(a)(1), pass-through entities must evaluate each subrecipient’s risk of noncompliance to determine the appropriate level of monitoring of the subrecipient. Per 2 CFR 200.332(d) through (f), pass-through entities must monitor the activities of the subrecipient, which includes reviewing financial reports required by the pass-through entity. Condition: During our testing, we noted subrecipients tested had required information omitted from the sub agreements to the subrecipients including Assistance Listing (CFDA) title and number, subrecipient’s DUNS number, Federal Award Identification Number (FAIN), identification of whether the award is research and development, and indirect cost rate for federal award. Subrecipients tested did not have evidence of the County’s evaluation of the risk of noncompliance by the subrecipients, nor was there evidence of monitoring of annual audits for the subrecipients. Internal checklists that aid in compliance were missing for certain subrecipients. Quarterly reports were also not submitted to the County by the subrecipients subsequent to funding. Questioned costs: None. Context: Five out of the five subrecipients did not include required information in subaward agreements issued to subrecipients and lacked evidence of both the evaluation of risk of noncompliance of the subrecipient and monitoring of annual audits for the subrecipients. One of the five subrecipients was missing an internal checklist that is signed by the County Manager. Five of the five subrecipients were provided the funding at the beginning of the grant award period and no required quarterly reports were submitted to the County subsequent to funding. Cause: Lack of sufficient controls in place to ensure that subrecipient agreements contain all required information and are monitored appropriately. Effect: Failure to communicate required information and to adequately monitor the subrecipients could result in subrecipients not properly administering the federal programs in accordance with federal regulations. Repeat Finding: Yes, repeat of prior year finding 2022-004. Recommendation: CLA recommends that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding and that appropriate monitoring is performed for each subrecipient. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR 200.331(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes, federal award identification, subrecipient name, subrecipient’s DUNS number, federal award identification number (FAIN), federal award date, subaward start and end date, amount of federal funds obligated, total amount of federal award, federal award project description, name of federal awarding agency, Assistance Listing (CFDA) number and name, identification of whether the award is R&D and indirect cost rate for federal award. Per 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 control should include procedures to ensure required information is communicated prior to the issuance of the subaward. Per 2 CFR 200.331(a)(1), pass-through entities must evaluate each subrecipient’s risk of noncompliance to determine the appropriate level of monitoring of the subrecipient. Per 2 CFR 200.332(d) through (f), pass-through entities must monitor the activities of the subrecipient, which includes reviewing financial reports required by the pass-through entity. Condition: During our testing, we noted subrecipients tested had required information omitted from the sub agreements to the subrecipients including Assistance Listing (CFDA) title and number, subrecipient’s DUNS number, Federal Award Identification Number (FAIN), identification of whether the award is research and development, and indirect cost rate for federal award. Subrecipients tested did not have evidence of the County’s evaluation of the risk of noncompliance by the subrecipients, nor was there evidence of monitoring of annual audits for the subrecipients. Internal checklists that aid in compliance were missing for certain subrecipients. Quarterly reports were also not submitted to the County by the subrecipients subsequent to funding. Questioned costs: None. Context: Five out of the five subrecipients did not include required information in subaward agreements issued to subrecipients and lacked evidence of both the evaluation of risk of noncompliance of the subrecipient and monitoring of annual audits for the subrecipients. One of the five subrecipients was missing an internal checklist that is signed by the County Manager. Five of the five subrecipients were provided the funding at the beginning of the grant award period and no required quarterly reports were submitted to the County subsequent to funding. Cause: Lack of sufficient controls in place to ensure that subrecipient agreements contain all required information and are monitored appropriately. Effect: Failure to communicate required information and to adequately monitor the subrecipients could result in subrecipients not properly administering the federal programs in accordance with federal regulations. Repeat Finding: Yes, repeat of prior year finding 2022-004. Recommendation: CLA recommends that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding and that appropriate monitoring is performed for each subrecipient. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 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 the required certifications for covered contracts and subawards are received, documented, and contracts are not made with a debarred or suspended party. Condition: During our testing of six covered transactions, we noted all vendors and subawards did not have proper supporting documentation for suspension and debarment procedures for vendors. Questioned costs: None. Context: All six covered transaction tested did not have proper supporting documentation for suspension and debarment procedures. Cause: Lack of sufficient controls in place to ensure that suspension and debarment checks were performed prior to entering into contracts. Effect: Failure to obtain the required certifications or perform verification procedures with the SAM could result in the payment of federal funds to vendors that are suspended or debarred from participation in federal assistance programs. Repeat Finding: Yes, repeat of prior year finding 2022-005. Recommendation: CLA recommends the County obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on SAM. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 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 the required certifications for covered contracts and subawards are received, documented, and contracts are not made with a debarred or suspended party. Condition: During our testing of six covered transactions, we noted all vendors and subawards did not have proper supporting documentation for suspension and debarment procedures for vendors. Questioned costs: None. Context: All six covered transaction tested did not have proper supporting documentation for suspension and debarment procedures. Cause: Lack of sufficient controls in place to ensure that suspension and debarment checks were performed prior to entering into contracts. Effect: Failure to obtain the required certifications or perform verification procedures with the SAM could result in the payment of federal funds to vendors that are suspended or debarred from participation in federal assistance programs. Repeat Finding: Yes, repeat of prior year finding 2022-005. Recommendation: CLA recommends the County obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on SAM. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 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 the required certifications for covered contracts and subawards are received, documented, and contracts are not made with a debarred or suspended party. Condition: During our testing of six covered transactions, we noted all vendors and subawards did not have proper supporting documentation for suspension and debarment procedures for vendors. Questioned costs: None. Context: All six covered transaction tested did not have proper supporting documentation for suspension and debarment procedures. Cause: Lack of sufficient controls in place to ensure that suspension and debarment checks were performed prior to entering into contracts. Effect: Failure to obtain the required certifications or perform verification procedures with the SAM could result in the payment of federal funds to vendors that are suspended or debarred from participation in federal assistance programs. Repeat Finding: Yes, repeat of prior year finding 2022-005. Recommendation: CLA recommends the County obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on SAM. Views of responsible officials: There is no disagreement with the audit finding.
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. Additionally, 2 CFR Appendix IV to Part 200 Section B.2(b) requires that both the direct costs and the indirect costs must exclude capital expenditures and unallowable costs. Per Compliance Supplement, these indirect costs must conform to the allowability of cost provisions in 2 CFR Part 200, Subpart E or award agreement. Condition: During our testing of indirect costs, we noted that the Corporation charges the Federally approved rate of 28.7% on specific grant awards based on direct salaries and wages. However, the Corporation did not maintain supporting indirect cost pools and related documentation. Cause: The Corporation did not have formal process and policies to demonstrate adherence to the allowability requirements of indirect costs in accordance with 2 CFR Appendix IV to Part 200 Section B.2(b). Effect or Potential Effect: We were unable to determine whether indirect costs charged to Federal awards conform to the allowability of cost provisions in 2 CFR Part 200, Subpart E or award agreement. Allowable costs incurred by the Corporation exceeded the amount of approved grant funding, therefore no questioned costs are reported. Questioned costs: Unknown Context: Management was not able to provide sufficient and appropriate evidence that the reported indirect costs conformed to the allowability of cost provisions in 2 CFR Part 200, Subpart E or award agreement. Repeat finding: This is a repeat finding from prior year. This was reported as finding 2022-016 in the 2022 report. Recommendation: We recommend the Corporation develop and incorporate internal controls and policies to demonstrate adherence to the allowability requirements of indirect costs in accordance with 2 CFR Appendix IV to Part 200 Section B.2(b). View of Responsible Officials: Due to turnover of several key financial executives and personnel, the Corporation did not maintain any supporting indirect cost pools and related documentation.
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. Additionally, 2 CFR Appendix IV to Part 200 Section B.2(b) requires that both the direct costs and the indirect costs must exclude capital expenditures and unallowable costs. Per Compliance Supplement, these indirect costs must conform to the allowability of cost provisions in 2 CFR Part 200, Subpart E or award agreement. Condition: During our testing of indirect costs, we noted that the Corporation charges the Federally approved rate of 28.7% on specific grant awards based on direct salaries and wages. However, the Corporation did not maintain supporting indirect cost pools and related documentation. Cause: The Corporation did not have formal process and policies to demonstrate adherence to the allowability requirements of indirect costs in accordance with 2 CFR Appendix IV to Part 200 Section B.2(b). Effect or Potential Effect: We were unable to determine whether indirect costs charged to Federal awards conform to the allowability of cost provisions in 2 CFR Part 200, Subpart E or award agreement. Allowable costs incurred by the Corporation exceeded the amount of approved grant funding, therefore no questioned costs are reported. Questioned costs: Unknown Context: Management was not able to provide sufficient and appropriate evidence that the reported indirect costs conformed to the allowability of cost provisions in 2 CFR Part 200, Subpart E or award agreement. Repeat finding: This is a repeat finding from prior year. This was reported as finding 2022-016 in the 2022 report. Recommendation: We recommend the Corporation develop and incorporate internal controls and policies to demonstrate adherence to the allowability requirements of indirect costs in accordance with 2 CFR Appendix IV to Part 200 Section B.2(b). View of Responsible Officials: Due to turnover of several key financial executives and personnel, the Corporation did not maintain any supporting indirect cost pools and related documentation.
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. Additionally, 2 CFR Appendix IV to Part 200 Section B.2(b) requires that both the direct costs and the indirect costs must exclude capital expenditures and unallowable costs. Per Compliance Supplement, these indirect costs must conform to the allowability of cost provisions in 2 CFR Part 200, Subpart E or award agreement. Condition: During our testing of indirect costs, we noted that the Corporation charges the Federally approved rate of 28.7% on specific grant awards based on direct salaries and wages. However, the Corporation did not maintain supporting indirect cost pools and related documentation. Cause: The Corporation did not have formal process and policies to demonstrate adherence to the allowability requirements of indirect costs in accordance with 2 CFR Appendix IV to Part 200 Section B.2(b). Effect or Potential Effect: We were unable to determine whether indirect costs charged to Federal awards conform to the allowability of cost provisions in 2 CFR Part 200, Subpart E or award agreement. Allowable costs incurred by the Corporation exceeded the amount of approved grant funding, therefore no questioned costs are reported. Questioned costs: Unknown Context: Management was not able to provide sufficient and appropriate evidence that the reported indirect costs conformed to the allowability of cost provisions in 2 CFR Part 200, Subpart E or award agreement. Repeat finding: This is a repeat finding from prior year. This was reported as finding 2022-016 in the 2022 report. Recommendation: We recommend the Corporation develop and incorporate internal controls and policies to demonstrate adherence to the allowability requirements of indirect costs in accordance with 2 CFR Appendix IV to Part 200 Section B.2(b). View of Responsible Officials: Due to turnover of several key financial executives and personnel, the Corporation did not maintain any supporting indirect cost pools and related documentation.
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. Additionally, 2 CFR Appendix IV to Part 200 Section B.2(b) requires that both the direct costs and the indirect costs must exclude capital expenditures and unallowable costs. Per Compliance Supplement, these indirect costs must conform to the allowability of cost provisions in 2 CFR Part 200, Subpart E or award agreement. Condition: During our testing of indirect costs, we noted that the Corporation charges the Federally approved rate of 28.7% on specific grant awards based on direct salaries and wages. However, the Corporation did not maintain supporting indirect cost pools and related documentation. Cause: The Corporation did not have formal process and policies to demonstrate adherence to the allowability requirements of indirect costs in accordance with 2 CFR Appendix IV to Part 200 Section B.2(b). Effect or Potential Effect: We were unable to determine whether indirect costs charged to Federal awards conform to the allowability of cost provisions in 2 CFR Part 200, Subpart E or award agreement. Allowable costs incurred by the Corporation exceeded the amount of approved grant funding, therefore no questioned costs are reported. Questioned costs: Unknown Context: Management was not able to provide sufficient and appropriate evidence that the reported indirect costs conformed to the allowability of cost provisions in 2 CFR Part 200, Subpart E or award agreement. Repeat finding: This is a repeat finding from prior year. This was reported as finding 2022-016 in the 2022 report. Recommendation: We recommend the Corporation develop and incorporate internal controls and policies to demonstrate adherence to the allowability requirements of indirect costs in accordance with 2 CFR Appendix IV to Part 200 Section B.2(b). View of Responsible Officials: Due to turnover of several key financial executives and personnel, the Corporation did not maintain any supporting indirect cost pools and related documentation.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.600, Department of Health and Human Services, Head Start and Covid-19: Head Start ARP Federal Award Identification Number and Year: 05CH011937-03-03, 05HE000989-01-01 Pass-through Entity – N/A Finding Type – Material weakness in internal control over compliance Repeat Finding – No Criteria – Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. Criteria - Grant and cooperative agreement recipients and contractors are required to register FSRS and report subaward data through FSRS. Compliance testing of the Transparency Act reporting requirements must include the following key data elements about the first-tier subrecipients and subawards under grants and cooperative agreements. Per 2 CFR section 200.303(a), a 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 – During our testing for reporting compliance, it was noted that the Organization did not submit the Federal Funding Accountability and Transparency Act report within the reporting timeline for prime grant recipients... Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The Organization’s procedures and controls were not sufficient to ensure that subawards were reported to FSRS during FY 2023. Subawards were not reported to FSRS in accordance with FFATA requirements. The Organization was required to report the subaward details above. The Organization was not required to report executive compensation. Recommendation – We recommend the Organization establish procedures and internal controls to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. View of Responsible Officials and Corrective Action Plan – The Agency agrees with this finding. As part of the subaward review process, the Chief Financial Officer will ensure that first tier subawards are checked to see if FFATA reporting is needed based on the award amount. If FFATA reporting is required, the Chief Financial Officer will assign this task to the Assistant Director for Financial Compliance to ensure that reporting is completed to the FFATA Reporting System FSRS.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.600, Department of Health and Human Services, Head Start and Covid-19: Head Start ARP Federal Award Identification Number and Year: 05CH011937-03-03, 05HE000989-01-01 Pass-through Entity – N/A Finding Type – Material weakness in internal control over compliance Repeat Finding – No Criteria – Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. Criteria - Grant and cooperative agreement recipients and contractors are required to register FSRS and report subaward data through FSRS. Compliance testing of the Transparency Act reporting requirements must include the following key data elements about the first-tier subrecipients and subawards under grants and cooperative agreements. Per 2 CFR section 200.303(a), a 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 – During our testing for reporting compliance, it was noted that the Organization did not submit the Federal Funding Accountability and Transparency Act report within the reporting timeline for prime grant recipients... Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The Organization’s procedures and controls were not sufficient to ensure that subawards were reported to FSRS during FY 2023. Subawards were not reported to FSRS in accordance with FFATA requirements. The Organization was required to report the subaward details above. The Organization was not required to report executive compensation. Recommendation – We recommend the Organization establish procedures and internal controls to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. View of Responsible Officials and Corrective Action Plan – The Agency agrees with this finding. As part of the subaward review process, the Chief Financial Officer will ensure that first tier subawards are checked to see if FFATA reporting is needed based on the award amount. If FFATA reporting is required, the Chief Financial Officer will assign this task to the Assistant Director for Financial Compliance to ensure that reporting is completed to the FFATA Reporting System FSRS.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 64.033, Department of Veteran Affairs, VA Supportive Services for Veteran Families Program Federal Award Identification Number and Year: 21-MI-221, 22-MI-221, 20-MI-221-SS, 20-MI-221-LT, 20-MI-221 Pass-through Entity – N/A Finding Type – Material weakness in internal control over compliance Repeat Finding – No Criteria – Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. Grant and cooperative agreement recipients and contractors are required to register FSRS and report subaward data through FSRS. Compliance testing of the Transparency Act reporting requirements must include the following key data elements about the first-tier subrecipients and subawards under grants and cooperative agreements. Criteria - Grant and cooperative agreement recipients and contractors are required to register FSRS and report subaward data through FSRS. Compliance testing of the Transparency Act reporting requirements must include the following key data elements about the first-tier subrecipients and subawards under grants and cooperative agreements. Per 2 CFR section 200.303(a), a 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 – During our testing for reporting compliance, it was noted that the Organization did not submit the Federal Funding Accountability and Transparency Act report within the reporting timeline for prime grant recipients. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The Organization’s procedures and controls were not sufficient to ensure that subawards were reported to FSRS during FY 2023. Subawards were not reported to FSRS in accordance with FFATA requirements. The Organization was required to report the subaward details above. The Organization was not required to report executive compensation. Recommendation – We recommend the Organization establish procedures and internal controls to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. View of Responsible Officials and Corrective Action Plan – The Agency agrees with this finding. As part of the subaward review process, the Chief Financial Officer will ensure that first tier subawards are checked to see if FFATA reporting is needed based on the award amount. If FFATA reporting is required, the Chief Financial Officer will assign this task to the Assistant Director for Financial Compliance to ensure that reporting is completed to the FFATA Reporting System FSRS.