Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Assistance Listing Number: 21.027 Program Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Federal Agency: United States Department of Treasury Pass-through Entity: N/A Federal Award Identification Number / Year: N/A / 2023 Criteria: Per CFR section 200.303, "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: Quarterly reports submitted to the United States Department of Treasury are not reviewed by someone other than the original preparer. Cause: The County has not established a formal process of review around reporting for grants received from the United States Department of Treasury. Effect: Eligible expenditure and other information included in the report submissions may include unidentified errors. Questioned Costs: None noted. Context: This represents a systemic matter as a formalized review process for reporting to the United States Department of Treasury does not exist. The sample of reports tested does not represent a statistically valid sample. Recommendation: We recommend the County implement formal, documented review controls around reports submitted to the United States Department of Treasury by someone other than the original preparer prior to submission. Management Response: Management has reviewed the finding and agrees.
COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – Federal Assistance Listing Number 20.027 Condition: We noted one disbursement of grant funds supported by a claim form with only one source of approval. Another disbursement was supported by a claim form with only one source of approval and the check issued was signed by only one authorized signer. Criteria: 2 CFR 200.303(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award. Also, CFR 200.302(b)(3) states the financial management system of each non-Federal entity must provide records that identify adequately, among other things, proper authorizations. Cause: Internal controls over cash disbursements were overridden. The County’s policy is to require two signatures on all checks, as well as a completed claim form which is approved by a department head, the county clerk, and a member of the claims committee. Effect: Unauthorized or improper use of grant funds could occur. Context: A total of thirteen disbursements was selected for testing, which was 100% of the population. The use of grant funds for the purpose of these disbursements was previously approved by the county board. Therefore, there are no questioned costs. Recommendation: Management should follow the internal control policies in effect for the disbursement of other County funds in the disbursement of CSLFRF grant funds. Views of Responsible Officials and Planned Corrective Actions: Management will follow controls implemented over approving claim forms and signing checks for other County disbursements for CSLFRF grant disbursements.
2023 – 003 Procurement and Suspension and Debarment Federal Agency: U.S. Department Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP3738 11/30/2021 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.318, 2 CFR 200.319, 2 CFR 200.324, 2 CFR 180.220, and 2 CFR 200.320,) requires a non-federal entity to maintain records sufficient to detail the history of procurement, the providing of full and open competition, the performing of cost or price analysis, and prohibits the non-federal entity to contract or make subawards to parties that are suspended or debarred (covered transactions over $25,000). These records will include the rationale for the method of procurement, selection of contract type, contractor selection or rejection, the basis for the contract price, how full and open competition was provided, the cost or price analysis performed, and verification the vendor is not suspended or debarred through the SAMs exclusion list, collecting of certification from the entity, or by adding a clause or condition to the covered transaction with the entity. Procurement methods used must be appropriate based on the dollar amount and conditions specified. Condition: Procurement methods for certain federal award purchases were not adequately documented or appropriately selected in accordance with the County’s procurement policy. In addition, the County did not maintain records the vendor was not suspended or debarred prior to entering into the transactions. Questioned costs: Unknown Context: 6 of 6 tested for procurement documentation and 6 of 6 tested for suspension and debarment documentation. Cause: With new federal funding opportunities due to the pandemic, and new guidance related to those grants, proper documentation was not retained. County policies have not been updated yet. Effect: May result in a disallowed cost if grant requirements are not followed. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-003. Recommendation: We recommend the County carefully review federal procurement requirements for proper documentation needed. The County should consider use of a Federal procurement checklist. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 004 Reporting Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP3738 11/30/2021 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit performance reports required by Federal award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the reported projects and expenditures accurately reflect what is reported in the expenditure detail and amounts obligated should reflect total procurement amounts awarded. Condition: While the correct expenditures were reported on the schedule of expenditures of federal awards, the expenditure reports filed during the year did not accurately report project details. Cumulative expenditures should report amounts expended through the end of the period and cumulative obligations should report total procurement amounts awarded. Questioned costs: None Context: The County incorrectly reported cumulative expenditures and cumulative obligations in 4 of 4 reports tested. Cause: Total cumulative expenditures were not reconciled to total amounts reported in the ledger. Reported project obligations were based on projects costs that been incurred and not contract sum awarded. Effect: Noncompliance with reporting requirements. Repeat Finding: This finding is a partial repeat of a finding in the prior year. The prior year finding number was 2022-004. Recommendation: We recommend the County strengthen its review procedures over reports. Total cumulative expenditures and total cumulative obligations reported should reconcile to the total amounts reported in the project accounting records used to support the SEFA. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 006 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds. Effective internal controls should include ensuring the reimbursement request are supported by documentation of expenditures that been incurred. Additionally, the time between receiving and disbursing federal funds should be minimized and interest should be calculated on amounts of unearned revenue. Condition: Supporting documentation for the cash drawdown requests were not maintained. There were instances in which the accounting records did not agree to the grant reimbursement request. The time between receiving and disbursing federal funds was not minimized and interest on unearned revenue was not calculated. Documentation of review and approval of the reimbursement request by an individual other than the preparer was not retained. Questioned costs: $1,237,948 Context: 8 of 8 cash reimbursement requests tested did not have supporting documentation of the exact amount received maintained. Cause: Support for the reimbursement request could not be provided over the individual cash request as it was not retained. Adjustments made to the project accounting records after the cash reimbursement request were made caused the County to receive more funds than expenses incurred on specific grants. Effect: Lack of proper documentation for reported information can lead to an over or under reimbursement of grant funds. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-006. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the reimbursement request and documentation be retained. Reconciliations should be reviewed and approved by an individual other than the preparer at the time of the request and this documentation should be retained. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 005 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 10/1/2022; G-2202ILLIEA 10/1/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 22-224038 Award Period: June 1, 2023 through September 30, 2024 and October 1, 2021 through June 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.308, 200.309, and 200.403(h)) requires non-federal entities charge only allowable costs incurred during the approved budget period of a general award’s period of performance. Effective internal controls should include procedures to ensure transactions for costs recorded for the beginning of the period of performance were not incurred prior to the start of the period of performance and transactions for cost recorded for the end of the period of performance were not incurred after the end of the period of performance for Federal awards. Condition: The County allocated costs to federal awards prior to the beginning of the period of performance and after the end of the period of performance. Questioned costs: $31,837 Context: 9 of 10 transactions tested were incurred prior to the period of performance and 1 of 15 transactions tested were incurred after the period of performance end date. Cause: Costs were inadvertently claimed that fell outside the period of performance. Effect: May result in unallowable costs being charged to the Federal program. Repeat Finding: This finding is a partial repeat of a finding in the prior year. The prior year finding number was 2022-005. Recommendation: We recommend the County review its procedures relative to allocating costs to Federal programs, and ensure only cost within the grant period are included. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 006 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds. Effective internal controls should include ensuring the reimbursement request are supported by documentation of expenditures that been incurred. Additionally, the time between receiving and disbursing federal funds should be minimized and interest should be calculated on amounts of unearned revenue. Condition: Supporting documentation for the cash drawdown requests were not maintained. There were instances in which the accounting records did not agree to the grant reimbursement request. The time between receiving and disbursing federal funds was not minimized and interest on unearned revenue was not calculated. Documentation of review and approval of the reimbursement request by an individual other than the preparer was not retained. Questioned costs: $1,237,948 Context: 8 of 8 cash reimbursement requests tested did not have supporting documentation of the exact amount received maintained. Cause: Support for the reimbursement request could not be provided over the individual cash request as it was not retained. Adjustments made to the project accounting records after the cash reimbursement request were made caused the County to receive more funds than expenses incurred on specific grants. Effect: Lack of proper documentation for reported information can lead to an over or under reimbursement of grant funds. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-006. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the reimbursement request and documentation be retained. Reconciliations should be reviewed and approved by an individual other than the preparer at the time of the request and this documentation should be retained. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 005 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 10/1/2022; G-2202ILLIEA 10/1/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 22-224038 Award Period: June 1, 2023 through September 30, 2024 and October 1, 2021 through June 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.308, 200.309, and 200.403(h)) requires non-federal entities charge only allowable costs incurred during the approved budget period of a general award’s period of performance. Effective internal controls should include procedures to ensure transactions for costs recorded for the beginning of the period of performance were not incurred prior to the start of the period of performance and transactions for cost recorded for the end of the period of performance were not incurred after the end of the period of performance for Federal awards. Condition: The County allocated costs to federal awards prior to the beginning of the period of performance and after the end of the period of performance. Questioned costs: $31,837 Context: 9 of 10 transactions tested were incurred prior to the period of performance and 1 of 15 transactions tested were incurred after the period of performance end date. Cause: Costs were inadvertently claimed that fell outside the period of performance. Effect: May result in unallowable costs being charged to the Federal program. Repeat Finding: This finding is a partial repeat of a finding in the prior year. The prior year finding number was 2022-005. Recommendation: We recommend the County review its procedures relative to allocating costs to Federal programs, and ensure only cost within the grant period are included. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 006 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds. Effective internal controls should include ensuring the reimbursement request are supported by documentation of expenditures that been incurred. Additionally, the time between receiving and disbursing federal funds should be minimized and interest should be calculated on amounts of unearned revenue. Condition: Supporting documentation for the cash drawdown requests were not maintained. There were instances in which the accounting records did not agree to the grant reimbursement request. The time between receiving and disbursing federal funds was not minimized and interest on unearned revenue was not calculated. Documentation of review and approval of the reimbursement request by an individual other than the preparer was not retained. Questioned costs: $1,237,948 Context: 8 of 8 cash reimbursement requests tested did not have supporting documentation of the exact amount received maintained. Cause: Support for the reimbursement request could not be provided over the individual cash request as it was not retained. Adjustments made to the project accounting records after the cash reimbursement request were made caused the County to receive more funds than expenses incurred on specific grants. Effect: Lack of proper documentation for reported information can lead to an over or under reimbursement of grant funds. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-006. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the reimbursement request and documentation be retained. Reconciliations should be reviewed and approved by an individual other than the preparer at the time of the request and this documentation should be retained. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 006 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds. Effective internal controls should include ensuring the reimbursement request are supported by documentation of expenditures that been incurred. Additionally, the time between receiving and disbursing federal funds should be minimized and interest should be calculated on amounts of unearned revenue. Condition: Supporting documentation for the cash drawdown requests were not maintained. There were instances in which the accounting records did not agree to the grant reimbursement request. The time between receiving and disbursing federal funds was not minimized and interest on unearned revenue was not calculated. Documentation of review and approval of the reimbursement request by an individual other than the preparer was not retained. Questioned costs: $1,237,948 Context: 8 of 8 cash reimbursement requests tested did not have supporting documentation of the exact amount received maintained. Cause: Support for the reimbursement request could not be provided over the individual cash request as it was not retained. Adjustments made to the project accounting records after the cash reimbursement request were made caused the County to receive more funds than expenses incurred on specific grants. Effect: Lack of proper documentation for reported information can lead to an over or under reimbursement of grant funds. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-006. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the reimbursement request and documentation be retained. Reconciliations should be reviewed and approved by an individual other than the preparer at the time of the request and this documentation should be retained. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP4201 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit performance reports required by Federal award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the reported projects and expenditures accurately reflect what is reported in the expenditure detail and amounts obligated should reflect total procurement amounts awarded. Condition: While the correct expenditures were reported on the schedule of expenditures of federal awards, the performance report filed during the year did not accurately report project details. Current period expenditures and obligations should have reported amounts expended and procurement amounts awarded during the reporting period and cumulative expenditure and obligations should have reported amounts expended and procurement amounts awarded from the start of the grant through the end of the reporting period. Questioned costs: None Context: 1 of 1 tested for reporting documentation. Cause: Total current period expenditures and obligations and total cumulated expenditures and obligations were not reconciled to the expenditure detail and procurement award detail. Prior period performance report overstated current period expenditures and obligations. These errors were corrected through current period performance report tested which causes current period expenditures and obligations to be understated. Effect: Cost could be disallowed as UGG not followed. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2022-005. Recommendation: We recommend the County perform a reconciliation of the project details reported to the expenditure detail and procurement amounts awarded detail used to support the SEFA, and these reconciliations be reviewed, to ensure accuracy and completeness of the reporting. Views of responsible officials: There is no disagreement with the audit finding.
2023-101 Lack of Internal Controls over the Application of the Sliding Fee Scale (prior two years 2022-101 and 2021-101) (initially reported 2014) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Special Tests and Provisions – Sliding Fee Discounts Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H8006452 (2022 and 2023), COVID-19 H8G48569 (2023) and COVID-19 ARP H8F40324 (2021) Finding Type: Material Weakness in Internal Control Questioned Costs: $0 Condition: The Organization lacks consistently applied processes and procedures related to the application of the sliding fee scale. The Organization also lacks a clear review process related to the sliding fee scale to identify errors quickly to allow for corrections to be made in a timely manner. - Sliding fee scales were not used for the agreement that the Organization has in place with the local school district in which they provide services to students. The agreement specifically does not allow the Organization to obtain information related to household size and income as needed to appropriately place the family on the sliding fee scale. The agreement also indicates no amounts can be collected from the students, except when that student has insurance which allows the Organization to bill the insurance company for a portion of the fees. - Sliding fee scales are not used in the disaster recovery bus program that does not charge the patients for services. - 14 of the sixty encounters sampled where the sliding scale was used had the wrong sliding fee scale applied based on information obtained about the patient’s family size and income. Four of the sixty encounters were for lab services which were not documented on the billing system and therefore the correct amount of the sliding scale fee could not be determined. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Health centers must prepare and apply a sliding fee discount schedule, so that the amounts owed for health center services by eligible patients are adjusted based on the patient's ability to pay (42 U.S.C 254b(k)(3)(G)(i)). The patient's ability to pay is based on the official poverty guidelines, as revised annually by the U.S. Department of Health and Human Services (42 U.S.C 9902(2)). Cause: Failure to apply the sliding fee correctly, as noted in six of the encounters above, was due to improper staff training or failure to properly monitor the process. Three of the encounters could not be determined for application of the correct sliding fee scale as lab fees were not documented in the billing system. Failure to apply the sliding fee scales due to the requirements of the agreement with the local school district and procedures applied to the disaster recovery bus program do not follow the written procedures of the Organization for use of the sliding fee scale. Effect: The Organization could be incorrectly billing for services and maintaining customer account balances at incorrect amounts. Recommendation: Staff should be consistently trained in how patients should complete the intake forms, including the sliding fee scale application, and require patients complete the form appropriately, including refusal to provide information, if applicable. Staff should also be consistently trained in what documentation is considered sufficient to support income identified as well as verify the application is consistent with the documentation and, when needed, clearly document the reasons for inconsistency. Staff should make every effort to obtain documentation of patient income in accordance with internal policies and procedures. Patients should be billed the usual and customary billing rates for all services until all documentation is received, or policies are adjusted to allow for self-determination by patients in certain situations. A process should be put in place to track patients to attempt further collection of the necessary data that would allow for adjustment of the bill after the fact when necessary. These exceptions should be tracked each month with the monthly review by the regional operations managers. The reviews by the regional operations managers should be documented and retained including the results and corrective action of the follow-up on deficiencies noted. The Organization should discuss with HRSA what could be done to either adjust policies and procedures used during the school visits to be compliant or obtain a waiver from HRSA to indicate their knowledge and approval of the school visits and disaster bus program visits not being compliant with the application of the sliding fee scale requirements. Views of Responsible Officials and Planned Corrective Actions: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Billing and Collections Policy was updated to waive co-pays for students in the School-Based Program. The Billing Department is in the process of auditing and implementing quarterly feedback & training sessions for the Operations Department for training and compliance for the Sliding Fee Discount Program. This process was implemented in 2025.
2023-102 Lack of Documentation Related to Reporting (prior two years 2022-108 and 2021-104) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H8006452 (2022 and 2023), H2E45500 (2022), COVID-19 ARP H8F40324 (2021), H8K49674 (2023), C1439909 (2020), H2E50094 (2023), COVID-19 H8L50549 (2023) and COVID-19 H8G48569 (2022) Finding Type: Significant Deficiency in Internal Control Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The accounting staff was restructured in November 2024 with the addition of a Finance Manager and Senior Accountant to strengthen internal controls and facilitate segregation of duties best practices for day-to-day activities. In addition to review of month-end journal entries, reporting requirements with additional review was also implemented in 2025.
2023-104 Lack of Controls Related to Filing Reports (initially reported 2023) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H8006452 (2022 and 2023), H2E45500 (2022), COVID-19 ARP H8F40324 (2021), H8K49674 (2023), C1439909 (2020), H2E50094 (2023), COVID-19 H8L50549 (2023) and COVID-19 H8G48569 (2022) Finding Type: Significant Deficiency in Internal Control Questioned Costs: $0 Condition: The Organization did not maintain proper documentation to support the review of the report prior to submission to the grantor, other than the review done by the preparer. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Cause: The Organization did not have a process in place for review of the data being reported on the HRSA website for the funds being expensed under the federal award programs. Effect: The Organization could submit incorrect information. Recommendation: The documentation should be kept that clearly documents who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The accounting staff was restructured in November 2024 with the addition of a Finance Manager and Senior Accountant to strengthen internal controls and facilitate segregation of duties best practices for day-to-day activities. In addition to review of month-end journal entries, reporting requirements with additional review was also implemented in 2025.
2023-105 Lack of Payroll Review and Approval (Also see financial statement finding 2023-004) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Period of Performance Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H8006452 (2022 and 2023), H2E45500 (2022), COVID-19 ARP H8F40324 (2021), H2E50094 (2023) and COVID-19 H8G48569 (2022) Finding Type: Material Weakness in Internal Control Questioned Costs: $0 Condition: No documentation of employee time approval by supervisors could be provided. The payroll clerk processes the payroll and the finance director approves through the releasing of the payroll. However, there is no formal documentation of the overall review of the payroll process and the supervisors’ approval of time recorded by employees. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards The requirement is for the Organization to have a process in place to correctly calculate, record, and pay payroll related expenses in accordance with grant and program requirements. Cause: The Organization does not have an effective process to review, approve, and document the supervisor’s approvals prior to making the payments. Effect: This situation provides an opportunity for errors and unauthorized transactions to occur and not be detected in a timely manner resulting in payroll expenses to be charged incorrectly to the federal awards. Recommendation: We recommend that the Organization begin using the approval feature in the Time Clock program to document the supervisor's approval of time for hourly employees. We also recommend that the Organization develop a process that includes and documents the review of payroll by an employee at least one level above the preparer prior to payment. Views of Responsible Officials and Planned Corrective Actions: The Organization has implemented a new payroll process using the ADP system. Employees are now required to approve their own time within the ADP portal, and this approval is documented. Following this, supervisors review and approve their employees’ time, which is also documented in the portal. Human Resources then prepares the payroll, reviewing all entries and initialing a shared file of payroll items and providing backup for changes. Once HR confirms accuracy, they notify Finance. Finance then reviews the payroll, with the Finance Manger providing the final approval within ADP once all items are confirmed. This entire process is fully documented, with approvals recorded within the ADP by employees and supervisors and the shared file drive where HR and Finance initial off on the reviewed payroll items, ensuring a traceable record of the entire payroll approval process.
2023-106 Missing Documentation to Support Payroll Authorizations (Initially reported 2023) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Allowable Activities and Costs Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H8006452 (2022 and 2023), H2E45500 (2022), COVID-19 ARP H8F40324 (2021), H2E50094 (2023) and COVID-19 H8G48569 (2022) Finding Type: Significant Deficiency in Internal Control Questioned Costs: $0 Condition: The Organization could not provide one salary authorization form for sample selection of 40 employees. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards Under compliance requirements for allowable activities and costs, management should ensure that costs can be supported by underlying accounting documentation. Cause: Filing errors resulting in staff being unable to provide the requested authorizations. Effect: The Organization would not be able to provide the related documentation to support allowable activities and costs under the program which could lead to loss in grant funding. Recommendation: We recommend that the Organization should put in a process to appropriately retain documentation to support allowable activities and costs under applicable grant programs. Views of Responsible Officials and Planned Corrective Actions: The Organization has implemented a process to ensure that all salary authorizations are properly obtained and stored. When there is any change in an employee's status or salary, an Employee Status Form is completed and signed by the employee, their supervisor, and Human Resources, and when required, by the COO and CEO. Additionally, the salary authorization form is added to a secure shared file drive. The shared file drive includes a section where all salary changes are listed. Both HR and Finance initial off to confirm that each salary change is supported by the proper documentation during the payroll review process.
2023-102 Lack of Documentation Related to Reporting (prior two years 2022-108 and 2021-104) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H8006452 (2022 and 2023), H2E45500 (2022), COVID-19 ARP H8F40324 (2021), H8K49674 (2023), C1439909 (2020), H2E50094 (2023), COVID-19 H8L50549 (2023) and COVID-19 H8G48569 (2022) Finding Type: Significant Deficiency in Internal Control Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The accounting staff was restructured in November 2024 with the addition of a Finance Manager and Senior Accountant to strengthen internal controls and facilitate segregation of duties best practices for day-to-day activities. In addition to review of month-end journal entries, reporting requirements with additional review was also implemented in 2025.