Finding No: 2023-002 Special Tests and Provisions - Enrollment Reporting Federal Agency: U.S. Department of Education Assistance Listing Number: 84.268 and 84.063 Program: Federal Direct Student Loan Program and Federal Pell Grant Program Award Year: July 1, 2022 through June 30, 2023 (a) Criteria or Requirement Institutions are required to report enrollment information under the Federal Pell Grant Program, the Federal Direct Student Loan Program and the Federal Family Education Loan Program, via the National Student Loan Data System (NSLDS) in accordance with 34 CFR 690.83(b)(2); 34 CFR 682.610; and 34 CFR 685.309. Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) Condition Found, Including Perspective During our enrollment reporting test work, we selected for testing a sample of 60 students awarded and disbursed Federal Pell Program (Pell) funds and/or Federal Direct Student Loan Program (Direct Loans) funds that had an enrollment change (i.e., dropped, withdrawn, or graduated) during fiscal year 2023. We noted one instance in which the student’s status change was submitted to the National Student Clearinghouse (NSC) and was subsequently rejected by the NSC due to inconsistent data related to the student’s social security number. The rejection of this student’s status change was included on an NSC Reject Detail Report for Fall 2022 through Fall 2023 and was not timely resolved and resubmitted by the University. As a result, we reviewed the cumulative NSC Reject Detail Report as of September 30, 2023 and noted 66 students with 132 instances of enrollment status rejections due to inconsistent data primarily related to social security numbers that had not been timely resolved and resubmitted. In addition, we noted one student selected for testing that was reported late to the NSLDS via the NSC due to management not maintaining a schedule to report every 60 days. As a result, we reviewed the enrollment report that included the student selected and identified an additional 60 students included on that enrollment report having an enrollment change that was reported late by the University (i.e,. outside of the 60-day period). For perspective, 10,058 students received Pell program funds and/or Direct Loan program funds during the 2022-2023 academic year. (c) Possible Cause The University's Registrar Office has a review process in place to review the NSC Reject Detail Report following the submission and processing of enrollment files to the NSC's website. However, the University does not reach out to the student to obtain verification or additional information to correct NSC rejections identified in the report that are related to social security number errors (i.e., NSC error code 290). The University's Registrar Office also has a process in place to maintain a transmission schedule on the NSC secure site. The schedule is set to report student enrollment status changes approximately 4 times each semester: 1) early registration is sent approximately one week before the start of the term; 2) first of term report is sent the day after Student Accounting cancels classes; 3) mid-term report is sent 45-60 days after the first of term submission; and 4) end of term transmission is sent within 60 days of the mid-term submission. An additional report is sent the next working day after the end of the add-back period for graduating students for degree verification, which is usually the last day before the start of the next term. As the student status change enrollment reports are not on a consistent reporting schedule to be submitted to the NSLDS via the NSC every 60 days, instances of untimely reporting of student enrollment status changes occurred. (d) Questioned Cost None reportable. (e) Effect As a result of management not resolving the student rejections on the NSC Reject Detail Report, the NSLDS was not notified of the student’s enrollment status change by the NSC as required. In addition, as a result of management not maintaining a consistent enrollment reporting schedule every 60 days, untimely reporting of students’ enrollment status changes to the NSLDS via the NSC occurred. (f) Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. (g) Repeat Finding in the Prior Year This finding is not a repeat finding. (h) Recommendation We recommend the University design a process and implement effective controls over the management review process of the NSC Reject Detail Report to prevent untimely resolution of all enrollment status change notification rejected by the NSC. We also recommend that the University Registrar's Office submit student status enrollment changes every 60 days based on the date the enrollment file was submitted, rather than the date the enrollment file was processed, to ensure timely reporting to the NSLDS via the NSC. (i) View of Responsible Officials Management concurs with the finding. The University Registrar will review the NSC Reject Detail Report every 45 days and will use the NSC error description resources to resolve any errors noted. In addition, the University Registrar's Office will submit student status enrollment changes every 30 days based on the date the enrollment file was submitted.
Finding No: 2023-002 Special Tests and Provisions - Enrollment Reporting Federal Agency: U.S. Department of Education Assistance Listing Number: 84.268 and 84.063 Program: Federal Direct Student Loan Program and Federal Pell Grant Program Award Year: July 1, 2022 through June 30, 2023 (a) Criteria or Requirement Institutions are required to report enrollment information under the Federal Pell Grant Program, the Federal Direct Student Loan Program and the Federal Family Education Loan Program, via the National Student Loan Data System (NSLDS) in accordance with 34 CFR 690.83(b)(2); 34 CFR 682.610; and 34 CFR 685.309. Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) Condition Found, Including Perspective During our enrollment reporting test work, we selected for testing a sample of 60 students awarded and disbursed Federal Pell Program (Pell) funds and/or Federal Direct Student Loan Program (Direct Loans) funds that had an enrollment change (i.e., dropped, withdrawn, or graduated) during fiscal year 2023. We noted one instance in which the student’s status change was submitted to the National Student Clearinghouse (NSC) and was subsequently rejected by the NSC due to inconsistent data related to the student’s social security number. The rejection of this student’s status change was included on an NSC Reject Detail Report for Fall 2022 through Fall 2023 and was not timely resolved and resubmitted by the University. As a result, we reviewed the cumulative NSC Reject Detail Report as of September 30, 2023 and noted 66 students with 132 instances of enrollment status rejections due to inconsistent data primarily related to social security numbers that had not been timely resolved and resubmitted. In addition, we noted one student selected for testing that was reported late to the NSLDS via the NSC due to management not maintaining a schedule to report every 60 days. As a result, we reviewed the enrollment report that included the student selected and identified an additional 60 students included on that enrollment report having an enrollment change that was reported late by the University (i.e,. outside of the 60-day period). For perspective, 10,058 students received Pell program funds and/or Direct Loan program funds during the 2022-2023 academic year. (c) Possible Cause The University's Registrar Office has a review process in place to review the NSC Reject Detail Report following the submission and processing of enrollment files to the NSC's website. However, the University does not reach out to the student to obtain verification or additional information to correct NSC rejections identified in the report that are related to social security number errors (i.e., NSC error code 290). The University's Registrar Office also has a process in place to maintain a transmission schedule on the NSC secure site. The schedule is set to report student enrollment status changes approximately 4 times each semester: 1) early registration is sent approximately one week before the start of the term; 2) first of term report is sent the day after Student Accounting cancels classes; 3) mid-term report is sent 45-60 days after the first of term submission; and 4) end of term transmission is sent within 60 days of the mid-term submission. An additional report is sent the next working day after the end of the add-back period for graduating students for degree verification, which is usually the last day before the start of the next term. As the student status change enrollment reports are not on a consistent reporting schedule to be submitted to the NSLDS via the NSC every 60 days, instances of untimely reporting of student enrollment status changes occurred. (d) Questioned Cost None reportable. (e) Effect As a result of management not resolving the student rejections on the NSC Reject Detail Report, the NSLDS was not notified of the student’s enrollment status change by the NSC as required. In addition, as a result of management not maintaining a consistent enrollment reporting schedule every 60 days, untimely reporting of students’ enrollment status changes to the NSLDS via the NSC occurred. (f) Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. (g) Repeat Finding in the Prior Year This finding is not a repeat finding. (h) Recommendation We recommend the University design a process and implement effective controls over the management review process of the NSC Reject Detail Report to prevent untimely resolution of all enrollment status change notification rejected by the NSC. We also recommend that the University Registrar's Office submit student status enrollment changes every 60 days based on the date the enrollment file was submitted, rather than the date the enrollment file was processed, to ensure timely reporting to the NSLDS via the NSC. (i) View of Responsible Officials Management concurs with the finding. The University Registrar will review the NSC Reject Detail Report every 45 days and will use the NSC error description resources to resolve any errors noted. In addition, the University Registrar's Office will submit student status enrollment changes every 30 days based on the date the enrollment file was submitted.
TRIO Cluster ‐ Assistance Listing # 84.042, 84.044, 84.047 U.S. Department of Education Federal Assistance Identification Number – P042A2A200272, P044A210475, P047A220386 Federal Award Year ‐ 2022 Criteria – As specified in 2 CFR section 200.303 the non‐Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐ Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Adequate controls must be in place to ensure that expenditures are properly authorized and allowable under program guidelines and are reported in the applicable reporting periods. Condition – The College’s internal control over compliance with allowable costs and activities requires that the terms of employment in the program be documented in an executed contract which details the terms of the employment. This control was not consistently adhered to for all employees. Cause – We noted three instances in a sample of sixteen employees in which an executed employment contract was not obtained to document the terms and approval of the employment under the program. Effect – Failure to follow the College’s policy of obtaining an executed contract for each employee under the program could result in disallowed costs. Questioned Costs – Not determinable. Recommendation – We recommend that the College strictly adhere to its policy of obtaining executed contracts for all employed under the program to ensure there is evidence of review and approval of employee contracts prior to payment. Management’s Response – The College will put into place controls that will provide assurance of proper review and approval of contracts for employees payroll disbursements prior to payment. The Dean of Business Affairs will be responsible for this corrective action and anticipates completion of corrective action will be taken before February 29, 2024.
TRIO Cluster ‐ Assistance Listing # 84.042, 84.044, 84.047 U.S. Department of Education Federal Assistance Identification Number – P042A2A200272, P044A210475, P047A220386 Federal Award Year ‐ 2022 Criteria – As specified in 2 CFR section 200.303 the non‐Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐ Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Adequate controls must be in place to ensure that expenditures are properly authorized and allowable under program guidelines and are reported in the applicable reporting periods. Condition – The College’s internal control over compliance with allowable costs and activities requires that the terms of employment in the program be documented in an executed contract which details the terms of the employment. This control was not consistently adhered to for all employees. Cause – We noted three instances in a sample of sixteen employees in which an executed employment contract was not obtained to document the terms and approval of the employment under the program. Effect – Failure to follow the College’s policy of obtaining an executed contract for each employee under the program could result in disallowed costs. Questioned Costs – Not determinable. Recommendation – We recommend that the College strictly adhere to its policy of obtaining executed contracts for all employed under the program to ensure there is evidence of review and approval of employee contracts prior to payment. Management’s Response – The College will put into place controls that will provide assurance of proper review and approval of contracts for employees payroll disbursements prior to payment. The Dean of Business Affairs will be responsible for this corrective action and anticipates completion of corrective action will be taken before February 29, 2024.
TRIO Cluster ‐ Assistance Listing # 84.042, 84.044, 84.047 U.S. Department of Education Federal Assistance Identification Number – P042A2A200272, P044A210475, P047A220386 Federal Award Year ‐ 2022 Criteria – As specified in 2 CFR section 200.303 the non‐Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐ Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Adequate controls must be in place to ensure that expenditures are properly authorized and allowable under program guidelines and are reported in the applicable reporting periods. Condition – The College’s internal control over compliance with allowable costs and activities requires that the terms of employment in the program be documented in an executed contract which details the terms of the employment. This control was not consistently adhered to for all employees. Cause – We noted three instances in a sample of sixteen employees in which an executed employment contract was not obtained to document the terms and approval of the employment under the program. Effect – Failure to follow the College’s policy of obtaining an executed contract for each employee under the program could result in disallowed costs. Questioned Costs – Not determinable. Recommendation – We recommend that the College strictly adhere to its policy of obtaining executed contracts for all employed under the program to ensure there is evidence of review and approval of employee contracts prior to payment. Management’s Response – The College will put into place controls that will provide assurance of proper review and approval of contracts for employees payroll disbursements prior to payment. The Dean of Business Affairs will be responsible for this corrective action and anticipates completion of corrective action will be taken before February 29, 2024.
Section III - Federal Award Findings and Questioned Costs Significant deficiency in internal controls over eligibility requirements. Federal Agency: United States Department of Labor AL Number/Title: 17.235/Senior Community Services Employment Program Pass-Through Entity: Goodwill Industries International Award Numbers: AD-33650-19-60-A24; AD-35214-20-60-A-24; 23A60AD000034-01-00; YF-39532-23-60-A-24 Criteria Per the standards contained in Title 2 US Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles and Audit Requirement for Federal Awards, Subpart D ‐ Post Federal Award Requirements, Section 200.303, non‐federal entities are required to 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. The Federal awards referenced require that eligible participants’ household earnings do not exceed specific income thresholds as outlined in Title 20 CFR, Section 641.500 and that participant eligibility is redetermined on an annual basis in accordance with Title 20 CFR Section 641.505. Condition/Context for Evaluation The Organization's internal compliance controls require that each participant’s household income is certified prior to admission to the program and then recertified annually thereafter in accordance with Title 20 CFR, Section 641.505. During testing for the year ended September 30, 2023, we noted that for two of the thirteen participants selected, while initial income certifications were performed, controls did not operate effectively to ensure the annual recertifications for the period under audit occurred. Eight of the thirteen selections required an annual recertification procedure. Questioned Costs Not applicable. Effect or Potential Effect Eligibility determinations were not completed in accordance with the requirements of the Federal awards. Cause The Organization’s internal controls over compliance did not operate effectively to recertify accurate eligibility determinations for participants. Repeat Finding Not applicable as no similar finding was noted in the prior year audit of the Organization.
Section III - Federal Award Findings and Questioned Costs Significant deficiency in internal controls over eligibility requirements. Federal Agency: United States Department of Labor AL Number/Title: 17.235/Senior Community Services Employment Program Pass-Through Entity: Goodwill Industries International Award Numbers: AD-33650-19-60-A24; AD-35214-20-60-A-24; 23A60AD000034-01-00; YF-39532-23-60-A-24 Criteria Per the standards contained in Title 2 US Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles and Audit Requirement for Federal Awards, Subpart D ‐ Post Federal Award Requirements, Section 200.303, non‐federal entities are required to 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. The Federal awards referenced require that eligible participants’ household earnings do not exceed specific income thresholds as outlined in Title 20 CFR, Section 641.500 and that participant eligibility is redetermined on an annual basis in accordance with Title 20 CFR Section 641.505. Condition/Context for Evaluation The Organization's internal compliance controls require that each participant’s household income is certified prior to admission to the program and then recertified annually thereafter in accordance with Title 20 CFR, Section 641.505. During testing for the year ended September 30, 2023, we noted that for two of the thirteen participants selected, while initial income certifications were performed, controls did not operate effectively to ensure the annual recertifications for the period under audit occurred. Eight of the thirteen selections required an annual recertification procedure. Questioned Costs Not applicable. Effect or Potential Effect Eligibility determinations were not completed in accordance with the requirements of the Federal awards. Cause The Organization’s internal controls over compliance did not operate effectively to recertify accurate eligibility determinations for participants. Repeat Finding Not applicable as no similar finding was noted in the prior year audit of the Organization.
Section III - Federal Award Findings and Questioned Costs Significant deficiency in internal controls over eligibility requirements. Federal Agency: United States Department of Labor AL Number/Title: 17.235/Senior Community Services Employment Program Pass-Through Entity: Goodwill Industries International Award Numbers: AD-33650-19-60-A24; AD-35214-20-60-A-24; 23A60AD000034-01-00; YF-39532-23-60-A-24 Criteria Per the standards contained in Title 2 US Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles and Audit Requirement for Federal Awards, Subpart D ‐ Post Federal Award Requirements, Section 200.303, non‐federal entities are required to 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. The Federal awards referenced require that eligible participants’ household earnings do not exceed specific income thresholds as outlined in Title 20 CFR, Section 641.500 and that participant eligibility is redetermined on an annual basis in accordance with Title 20 CFR Section 641.505. Condition/Context for Evaluation The Organization's internal compliance controls require that each participant’s household income is certified prior to admission to the program and then recertified annually thereafter in accordance with Title 20 CFR, Section 641.505. During testing for the year ended September 30, 2023, we noted that for two of the thirteen participants selected, while initial income certifications were performed, controls did not operate effectively to ensure the annual recertifications for the period under audit occurred. Eight of the thirteen selections required an annual recertification procedure. Questioned Costs Not applicable. Effect or Potential Effect Eligibility determinations were not completed in accordance with the requirements of the Federal awards. Cause The Organization’s internal controls over compliance did not operate effectively to recertify accurate eligibility determinations for participants. Repeat Finding Not applicable as no similar finding was noted in the prior year audit of the Organization.
Section III - Federal Award Findings and Questioned Costs Significant deficiency in internal controls over eligibility requirements. Federal Agency: United States Department of Labor AL Number/Title: 17.235/Senior Community Services Employment Program Pass-Through Entity: Goodwill Industries International Award Numbers: AD-33650-19-60-A24; AD-35214-20-60-A-24; 23A60AD000034-01-00; YF-39532-23-60-A-24 Criteria Per the standards contained in Title 2 US Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles and Audit Requirement for Federal Awards, Subpart D ‐ Post Federal Award Requirements, Section 200.303, non‐federal entities are required to 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. The Federal awards referenced require that eligible participants’ household earnings do not exceed specific income thresholds as outlined in Title 20 CFR, Section 641.500 and that participant eligibility is redetermined on an annual basis in accordance with Title 20 CFR Section 641.505. Condition/Context for Evaluation The Organization's internal compliance controls require that each participant’s household income is certified prior to admission to the program and then recertified annually thereafter in accordance with Title 20 CFR, Section 641.505. During testing for the year ended September 30, 2023, we noted that for two of the thirteen participants selected, while initial income certifications were performed, controls did not operate effectively to ensure the annual recertifications for the period under audit occurred. Eight of the thirteen selections required an annual recertification procedure. Questioned Costs Not applicable. Effect or Potential Effect Eligibility determinations were not completed in accordance with the requirements of the Federal awards. Cause The Organization’s internal controls over compliance did not operate effectively to recertify accurate eligibility determinations for participants. Repeat Finding Not applicable as no similar finding was noted in the prior year audit of the Organization.
Department of Health and Human Services Federal Assistance Listing #93.498 COVID‐19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 4 TIN #411271856 Activities Allowed or Unallowed and Allowable Costs/Costs Principles Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The Organization selected option iii to calculate lost revenue, which consists of utilizing an alternative reasonable method. Condition: The Organization selected option iii to calculate lost revenue using budgeted net revenues to actual net revenues. The Organization utilized net revenues for part of the calculation and then utilized gross revenues in later quarters. This inconsistency of net and gross revenues caused a miscalculation of the Organization’s total lost revenue. Cause: These errors indicate there is a lack of policies governing the review and approval of the lost revenue calculation to its supporting documents. Effect: The Organization did not follow their methodology for calculating lost revenues, resulting in overstating the amount of lost revenues to be claimed by $282,934. While the Organization had an error in the total amount of lost revenue calculated, the Organization has excess amounts of lost revenues to carryforward of $3,663,347. Questioned Costs: None reported. Context: Lost revenue was tested for all twelve quarters that were reported. Controls did not appear to be operating effectively for three of the quarters tested. Repeat Finding from Prior Years: No Recommendation: We recommend that the Organization enhance internal control policies to ensure that the lost revenue calculation follows the selected lost revenue methodology per the Organization’s memo. Views of Responsible Officials: Management agrees with the finding.
Department of Health and Human Services Federal Assistance Listing #93.498 COVID‐19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 4 TIN #411271856 Reporting Material Weakness in Internal Control Over Compliance and Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The Organization is required to submit an accurate report to HHS for each filing period that funds were received. Condition: The Organization utilized net revenues and gross revenues in the lost revenue calculation causing errors in the lost revenue calculation which resulted in key line items being reported incorrectly in the Period 4 HHS Report. Cause: These key line item errors indicate there is a lack of policies governing the review and approval of the HHS Report to its supporting documents (i.e. lost revenue calculations). Effect: The Organization did not follow their methodology for calculating lost revenues, resulting in overstating the amount of lost revenues to be claimed by $282,934. While the Organization had an error in the total amount of lost revenue calculated, the Organization has excess amounts of lost revenues to carryforward of $3,663,347. As a result of the error in calculation, there were three key line items on the Period 4 HHS Report that were incorrect. Questioned Costs: None reported. Context: All key line items on the HHS Period 4 Report were tested. Of the twelve key line items tested related to lost revenue, three line items contained errors. Repeat Finding from Prior Years: No Recommendation: We recommend the Organization enhance internal control policies to ensure the HHS Report is properly reviewed prior to submission to ensure all key line items are necessary, correct, meet the requirements of the federal program, and are properly supported. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: Department of Health and Human Services Federal Program Name: Chafee Education and Training Vouchers Program Assistance Listing Number: 93.599 Pass-Through Agency: MN Dept. of Human Services Pass-Through Number: GRK%157729 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR 200.303 requires that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our audit testing, we noted that there was not evidence of an internal control (supervisor approval of time and effort charged to the federal grant) for some transactions. Context: We tested 12 payroll time and effort reports. We were provided documentation supporting the time charged to the grant, but there was not evidence of a supervisory review on 6 of the reports. Cause: Time and effort reports were reviewed by a supervisor, who then sent to an email inbox once they approved. We were able to view the email approvals for recent time periods, however, emails were deleted in the system after six months so we were unable to view the approval from earlier in the year. Effect: Internal controls were not properly documented. Repeat finding: Not a repeat finding Recommendation: We recommend the Organization put procedures in place to retain documentation of supervisory approval of time and effort reports. Views of responsible officials: There is no disagreement with the audit finding.
Space Operations Assistance Listing Number: 43.007 Federal Award ID Number: 80JSC018M0005 National Aeronautics and Space Administration 2023 Funding Criteria: Competitive Procurement: 2 CFR Section 200.320 and 48 CFR section 52.244-5 sets forth the requirements for acquisition contracts awarded to vendors including the requirement to obtain price or rate quotations from an adequate number of qualified sources and the circumstances in which noncompetitive procurement methods can be used. Also, CASIS’s procurement policy states that it is in both CASIS and NASA’s interest to compete when it makes sense regardless of the threshold and can be achieved by obtaining three quotes, i.e., comparative shopping. A minimum of 3 vendors are required to demonstrate competition. CASIS may solicit a proposal from only one source in circumstances where one or more of the following conditions apply (FAR Subpart 6.3): (i) The item or service is available only from a single source. (ii) An unanticipated exigency or emergency exists that requires the equipment, materials, supplies or services to be procured immediately. (iii) NASA specifically authorizes the use of noncompetitive proposals (directed source). (iv) After consultation with a number of sources, competition is determined inadequate. (v) The vendor is listed as a sole source provider under the Cooperative Agreement. Vendor disbursements: 2 CFR section 200.214 and 2 CFR section 180.300 require non-federal entities restrict awards, subawards, and contracts with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Internal controls: 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with the Uniform Guidance. - 10 - Condition: Competitive quotes were not obtained for one expense, and sole source determination was not documented for another expense. In addition, for one vendor there was no check performed to ensure it was not debarred prior to the purchase approval. Cause: For one expense, CASIS did not obtain competitive quotes as required per their policy. CASIS had used the venue for meetings in the past, and did not obtain additional quotes for this event. This is a control and compliance deficiency. For another expense tested in the sample, no documentation of this being a sole source purchase prior to expending the funds. This expense is for a membership and essentially has a single provider. This is a control deficiency, but not a compliance issue. For one vendor, CASIS did not perform SAM check prior to approving the purchase. Vendor search at SAM.gov, subsequent to year end, revealed that the vendor is not debarred. This is a control deficiency, but not a compliance issue. Effect: If CASIS cannot demonstrate that procurements were made with full and open competition, properly sole sourced, and vendors are not debarred, it can result in questioned costs and funds being returned to NASA. Questioned Costs: Known questioned costs of $17,967, and likely questioned costs of $25,293. Perspective: For open competition there were 2 out of 60 expenses selected that the control failed. There was one vendor out of 10 selected that the debarment check was not performed. Recommendation: Competitive quotes should be obtained and retained as specified in the procurement policy. Non-competitive procurement should be documented and approved prior to incurring expenses. Vendor debarment checks should be performed and documented prior to entering into covered transactions. Management Response: The audit uncovered a non-compliance with required competitive quotes for a procurement of meeting services which did not comply with CASIS policy. The predecessor management team had previously advised the responsible purchaser that these services did not require competitive quotes. This matter is also complicated by the fact that the procurements are not just for meeting space, logistics and meals, but also includes lodging, which is not subject to the three quote rule. Management acknowledges that this was a process escapement and provides for the following corrective action. Typically lodging expenses are included in the procurement because it results in discounts that are unavailable if not included. CASIS implemented a policy of requiring competitive quotes for purchases over $1,000 in the most recent revision of the procurement policy. This change was made to assure compliance with Federal Regulations. While the amount noted is within the limits established by Federal Micro- purchase regulations, it did not comply with internal policies as noted. Meeting space is a commonly used service that is highly competitive in pricing and most facilities charge competitive rates, but most of the time those quotes are not useable given the time of year, and more importantly the occupancy rate of the facility. Starting in 2024, we are requesting quotes from three facilities in the local area that will be valid for a period of one year. These rates will be updated manually and a single additional quote will be obtained to assure the “reasonableness” of the price. This process will represent an annual price survey that will satisfy the three quote rule of our procurement policy. For rental of facilities outside of the local area, we will obtain a minimum of three quotes as required by our procurement policy. Management also acknowledges the process escapement for SAM checks on new vendors. Our normal process is that annually, Finance performs a SAM check for all approved vendors. The agreement for Trust Factory came in late during the year resulting in this deficiency. When a new vendor is setup in our system, it will automatically trigger a SAM check.
2023-001 U.S. Department of Housing and Urban Development Federal Financial Assistance Listing 14.267 Continuum of Care Program Program Income Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: There was not a documented review by a separate individual outside of the preparer of the program income calculations. Cause: The Housing Authority had a review process in place over program income calculations. However, the review process was not documented. Effect: Without a documented review and approval, there is a possibility for errors in the calculation of program income. Questioned Costs: None reported Context/Sampling: A nonstatistical sample of 13 participants out of 65 participants were selected for program income testing. Repeat Finding from Prior Year: No Recommendation: We recommend the Housing Authority to implement a documentation process around the review and approval of program income calculations. Views of Responsible Officials: Management agrees with the finding.
Department of Health and Human Services Federal Financial Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan Applicable Federal Award Number and Year – Period 4 TIN #860107344 Reporting Material Weakness in Internal Control Over Compliance and Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Hospital did not consider the impact of the year-end audit adjustments on the quarters applicable to Period 4 when reporting lost revenue. Cause: The established internal controls did not consider the effect of the year-end audit adjustments by quarter for Period 4 to ensure accurate quarterly reporting of net patient revenue. Effect: The lack of adequate policies governing report preparation and submission increases the risk that the report could be filed incorrectly. Questioned Costs: None reported relating to Period 4 as eligible expenditures and lost revenues exceeded Period 4 funds received. However, future amounts eligible for lost revenues is overstated by $63,347 on the Period 4 report. Context: There are 16 key line items related to lost revenue which were tested on the Period 4 Department of Health and Human Services special report. 4 of the 16 key line items did not actually represent net patient service revenue. Repeat Finding from Prior Years: Yes, prior year finding 2022-003 Recommendation: We recommend that the Hospital strengthen the control process relating to calculating quarterly lost revenue under the federal program. Views of Responsible Officials: Management agrees with the finding.
Department of Health and Human Services Federal Financial Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan Applicable Federal Award Number and Year – Period 4 TIN #860107344 Activities Allowed/Allowable Costs Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Hospital’s expenditures identified as eligible and claimed under the Provider Relief Fund program did not agree to the underlying detail listing. The current key financial personnel were unable to reconcile the differences between the support and the amounts reported. Cause: There was turnover in key financial positions. The established internal controls did not ensure the underlying detail supported expenditures identified as eligible and claimed. Effect: The lack of adequate policies governing report preparation and submission increases the risk that the report could be filed incorrectly. Questioned Costs: None reported relating to Period 4 as total eligible expenditures on the underlying detail listing exceeded amount of Period 4 funds received. Context: A total non-statistical sample of 60 transactions were tested which accounted for $2,558,991 of $3,645,080 identified on the detail listing. This exceeded the $2,074,204 of funds received in Period 4. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Hospital strengthen the control process for maintaining documentation of the final expenditure listing used to claim the allowable costs under the federal program. Views of Responsible Officials: Management agrees with the finding.
Department of Health and Human Services Federal Financial Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan Applicable Federal Award Number and Year – Period 4 TIN #860107344 Reporting Material Weakness in Internal Control Over Compliance and Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Hospital’s expenditures reported as eligible and claimed under the Provider Relief Fund program did not agree to the underlying detail listing. The current key financial personnel were unable to reconcile the differences between the support and the amounts reported. Cause: There was turnover in key financial positions. The established internal controls did not ensure the underlying detail supported expenditures reported for Period 4. Effect: The lack of adequate policies governing report preparation and submission increases the risk that the report could be filed incorrectly. Questioned Costs: None reported relating to Period 4 as total eligible expenditures on the underlying detail listing exceeded amount of Period 4 funds received. Context: The key line item related to total Provider Relief Expenses was tested on the Period 4 Department of Health and Human Services special report. Repeat Finding from Prior Years: No Recommendation: We recommend that the Hospital strengthen the control process for maintaining documentation of the final expenditure listing used to report under the federal program. Views of Responsible Officials: Management agrees with the finding.
S3800-010 Finding Reference Number – 2023-002 S3800-011 Title and CFDA Number of Federal Program – Section 232 Loan – Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities Loan, ALN 14.129 S3800-015 Type of Finding – Federal Award Finding Other Matters S3800-016 Finding Resolution Status – In progress S3800-017 Information on Universe Population Size – 1,710 checks and bank transfers, all disbursements from bank accounts. S3800-018 Sample Size Information – Sample size was 49 disbursements. Errors were found on 2 out of the 49 disbursements tested. S3800-019 Identification of Repeat Finding and Finding Reference Number – N/A S3800-020 Criteria – Per 2 CFR sections 200.302 and 200.303 of the Uniform Guidance, an entity must establish and maintain effective internal control over the federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations and terms and conditions of the federal award. Allowable cost controls of Cheney Care Community require general ledger account coding to be written on each invoice to be reviewed by the Executive Director before the invoice is processed to be paid. S3800-030 Statement of Condition – During our audit, we noted two invoices that did not include the general ledger account coding on the invoices, as required by Cheney Care Community’s allowable cost controls. The invoices were recorded to the proper general ledger accounts. S3800-032 Cause – Cheney Care Community did not follow their documented internal controls over financial reporting and allowable costs to ensure general ledger coding is included on each invoice for review and approval. S3800-033 Effect or Potential Effect – Failure to maintain effective internal controls over compliance with federal requirements increases the risk of unauthorized or unallowable transactions occurring. S3800-035 Auditor Non-Compliance Code – S (Internal Controls) S3800-037 FHA/Contract Number – 171-22029 S3800-038 Questioned Costs – $0 S3800-040 Questioned Costs – $0 S3800-045 Reporting Views of Responsible Officials – Cheney Care Community is in agreement with the findings, and the recommendations have been implemented. S3800-050 Context – A sample of 49 checks totaling $206,327 was selected for audit from a population of 1,710 checks totaling $11,294,298. The test found two checks that were not in compliance with Cheney Care Community’s allowable cost controls totaling $93. The invoices were recorded to the proper general ledger accounts. Our sample was a statistically valid sample. S3800-080 Recommendation – We recommend management of Cheney Care Community review their internal controls over the cash disbursement process with the necessary individuals involved in the process to ensure the implementation of general ledger account coding on cash disbursements is consistently performed going forward. S3800-090 Auditor’s Summary of Auditee Comments on the Findings and Recommendations – The Executive Director and A/P Clerk agreed upon using certain general ledger account codes consistently for similar purchases from the same vendor. In Cheney Care Community’s accounting system, these agreed upon general ledger account codes have been pre-set as a default for certain vendors. When invoices are received that should be appropriately coded to this default general ledger account code, errors of not documenting the general ledger account code on the invoice are periodically made. Cheney Care Community will consistently perform the general ledger account coding internal control procedures on invoices going forward. S3800-130 Response Indicator – Agree S3800-140 Completion Date – September 30, 2024 S3800-150 Response – Cheney Care Community will consistently perform the general ledger account coding internal control procedures on invoices going forward.
S3800-010 Finding Reference Number – 2023-002 S3800-011 Title and CFDA Number of Federal Program – Section 202 Supportive Housing for the Elderly, Capital Advance and Project Rental Assistance Contract, ALN 14.157 S3800-015 Type of Finding – Federal Award Finding; Other Matters S3800-016 Finding Resolution Status – In progress S3800-017 Information on Universe Population Size – 202 checks and bank transfers, all disbursements from bank accounts S3800-018 Sample Size Information – Sample size was 40 disbursements. Errors were found on 1 out of the 40 disbursements tested. S3800-019 Identification of Repeat Finding and Finding Reference Number – N/A S3800-020 Criteria – Per 2 CFR sections 200.302 and 200.303 of the Uniform Guidance, an entity must establish and maintain effective internal control over the federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations and terms and conditions of the federal award. Allowable cost controls of Sessions Village 202 require general ledger account coding to be written on each invoice to be reviewed by the Executive Director before the invoice is processed to be paid. S3800-030 Statement of Condition – During our audit, we noted one invoice that did not include the general ledger account coding on the invoice, as required by Sessions Village 202’s allowable cost controls. The invoice was recorded to the proper general ledger account. S3800-032 Cause – Sessions Village 202 did not follow their documented internal controls over financial reporting and allowable costs to ensure general ledger coding is included on each invoice for review and approval. S3800-033 Effect or Potential Effect – Failure to maintain effective internal controls over compliance with federal requirements increases the risk of unauthorized or unallowable transactions occurring. S3800-035 Auditor Non-Compliance Code – S (Internal Controls) S3800-037 FHA/Contract Number – 171-EE015 S3800-038 Questioned Costs – $0 S3800-040 Questioned Costs – $0 S3800-045 Reporting Views of Responsible Officials – Sessions Village 202 is in agreement with the findings, and the recommendations have been implemented. S3800-050 Context – A sample of 40 checks totaling $41,900 was selected for audit from a population of 202 checks totaling $186,253. The test found one check that was not in compliance with Sessions Village 202’s allowable cost controls totaling $369. The invoice was recorded to the proper general ledger account. Our sample was a statistically valid sample. S3800-080 Recommendation – We recommend management of Sessions Village 202 review their internal controls over the cash disbursement process with the necessary individuals involved in the process to ensure the implementation of general ledger account coding on cash disbursements is consistently performed going forward. S3800-090 Auditor’s Summary of Auditee Comments on the Findings and Recommendations – The Executive Director and A/P Clerk agreed upon using certain general ledger account codes consistently for similar purchases from the same vendor. In Sessions Village 202’s accounting system, these agreed upon general ledger account codes have been pre-set as a default for certain vendors. When invoices are received that should be appropriately coded to this default general ledger account code, errors of not documenting the general ledger account code on the invoice are periodically made. Sessions Village 202 will consistently perform the general ledger account coding internal control procedures on invoices going forward. S3800-130 Response Indicator – Agree S3800-140 Completion Date – September 30, 2024 S3800-150 Response – Sessions Village 202 will consistently perform the general ledger account coding internal control procedures on invoices going forward.
S3800-010 Finding Reference Number – 2023-002 S3800-011 Title and CFDA Number of Federal Program – Section 202 Supportive Housing for the Elderly, Capital Advance and Project Rental Assistance Contract, ALN 14.157 S3800-015 Type of Finding – Federal Award Finding; Other Matters S3800-016 Finding Resolution Status – In progress S3800-017 Information on Universe Population Size – 202 checks and bank transfers, all disbursements from bank accounts S3800-018 Sample Size Information – Sample size was 40 disbursements. Errors were found on 1 out of the 40 disbursements tested. S3800-019 Identification of Repeat Finding and Finding Reference Number – N/A S3800-020 Criteria – Per 2 CFR sections 200.302 and 200.303 of the Uniform Guidance, an entity must establish and maintain effective internal control over the federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations and terms and conditions of the federal award. Allowable cost controls of Sessions Village 202 require general ledger account coding to be written on each invoice to be reviewed by the Executive Director before the invoice is processed to be paid. S3800-030 Statement of Condition – During our audit, we noted one invoice that did not include the general ledger account coding on the invoice, as required by Sessions Village 202’s allowable cost controls. The invoice was recorded to the proper general ledger account. S3800-032 Cause – Sessions Village 202 did not follow their documented internal controls over financial reporting and allowable costs to ensure general ledger coding is included on each invoice for review and approval. S3800-033 Effect or Potential Effect – Failure to maintain effective internal controls over compliance with federal requirements increases the risk of unauthorized or unallowable transactions occurring. S3800-035 Auditor Non-Compliance Code – S (Internal Controls) S3800-037 FHA/Contract Number – 171-EE015 S3800-038 Questioned Costs – $0 S3800-040 Questioned Costs – $0 S3800-045 Reporting Views of Responsible Officials – Sessions Village 202 is in agreement with the findings, and the recommendations have been implemented. S3800-050 Context – A sample of 40 checks totaling $41,900 was selected for audit from a population of 202 checks totaling $186,253. The test found one check that was not in compliance with Sessions Village 202’s allowable cost controls totaling $369. The invoice was recorded to the proper general ledger account. Our sample was a statistically valid sample. S3800-080 Recommendation – We recommend management of Sessions Village 202 review their internal controls over the cash disbursement process with the necessary individuals involved in the process to ensure the implementation of general ledger account coding on cash disbursements is consistently performed going forward. S3800-090 Auditor’s Summary of Auditee Comments on the Findings and Recommendations – The Executive Director and A/P Clerk agreed upon using certain general ledger account codes consistently for similar purchases from the same vendor. In Sessions Village 202’s accounting system, these agreed upon general ledger account codes have been pre-set as a default for certain vendors. When invoices are received that should be appropriately coded to this default general ledger account code, errors of not documenting the general ledger account code on the invoice are periodically made. Sessions Village 202 will consistently perform the general ledger account coding internal control procedures on invoices going forward. S3800-130 Response Indicator – Agree S3800-140 Completion Date – September 30, 2024 S3800-150 Response – Sessions Village 202 will consistently perform the general ledger account coding internal control procedures on invoices going forward.
Material Weakness- Internal Controls over Reporting and Noncompliance Department of Housing and Urban Development - Direct Program - CDBG Entitlement Grants Cluster-ALN 14.218 - Program Year 2023 Criteria- 2 CFR section 200.303 - Internal Controls of the Uniform Guidance states that the non-federal entity must (a) establish and maintain effective internal controls over federal award that provides reasonable assurance that the non-federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in "Standards in Internal Control in the Federal Government" issued by the Comptroller General of the United States of the "Internal Control by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)". 2 CFR Part 170 requires non-federal entities making first-tier subawards of federal funding to comply with the reporting requirements of the Federal Funding Accountability and Transparency Act of 2006 (FFATA) (Public Law 109-282), as amended by section 6202 of Public Law 110-252. Compliance with FFATA requires prime recipients, to report certain information about subawards to the FFATA Subaward Reporting System (FSRS) by the end of the month, plus 30 days, in which the award is made. Condition- The County did not report required information about subawards made under Assistance Listing No. 14.218 to the FSRS as required by FFATA within the timeline required. There were 7 subawards not report representing $2,417,617 in total. Cause/ Effect - The County did no have internal controls in place to ensure accurate and timely subaward information is reported to the FSRS. Questioned Costs- None Auditor's Recommendation - We recommend that the County have policies in place to ensure information si report to the FSRS as required by FFATA. Management Response - See Corrective Action Plan Letter
Material Weakness- Internal Controls over Reporting and Noncompliance Department of Housing and Urban Development - Direct Program - CDBG Entitlement Grants Cluster-ALN 14.218 - Program Year 2023 Criteria- 2 CFR section 200.303 - Internal Controls of the Uniform Guidance states that the non-federal entity must (a) establish and maintain effective internal controls over federal award that provides reasonable assurance that the non-federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in "Standards in Internal Control in the Federal Government" issued by the Comptroller General of the United States of the "Internal Control by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)". 2 CFR Part 170 requires non-federal entities making first-tier subawards of federal funding to comply with the reporting requirements of the Federal Funding Accountability and Transparency Act of 2006 (FFATA) (Public Law 109-282), as amended by section 6202 of Public Law 110-252. Compliance with FFATA requires prime recipients, to report certain information about subawards to the FFATA Subaward Reporting System (FSRS) by the end of the month, plus 30 days, in which the award is made. Condition- The County did not report required information about subawards made under Assistance Listing No. 14.218 to the FSRS as required by FFATA within the timeline required. There were 7 subawards not report representing $2,417,617 in total. Cause/ Effect - The County did no have internal controls in place to ensure accurate and timely subaward information is reported to the FSRS. Questioned Costs- None Auditor's Recommendation - We recommend that the County have policies in place to ensure information si report to the FSRS as required by FFATA. Management Response - See Corrective Action Plan Letter
Material Weakness- Internal Controls over Reporting and Noncompliance Department of Housing and Urban Development - Direct Program - CDBG Entitlement Grants Cluster-ALN 14.218 - Program Year 2023 Criteria- 2 CFR section 200.303 - Internal Controls of the Uniform Guidance states that the non-federal entity must (a) establish and maintain effective internal controls over federal award that provides reasonable assurance that the non-federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in "Standards in Internal Control in the Federal Government" issued by the Comptroller General of the United States of the "Internal Control by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)". 2 CFR Part 170 requires non-federal entities making first-tier subawards of federal funding to comply with the reporting requirements of the Federal Funding Accountability and Transparency Act of 2006 (FFATA) (Public Law 109-282), as amended by section 6202 of Public Law 110-252. Compliance with FFATA requires prime recipients, to report certain information about subawards to the FFATA Subaward Reporting System (FSRS) by the end of the month, plus 30 days, in which the award is made. Condition- The County did not report required information about subawards made under Assistance Listing No. 14.218 to the FSRS as required by FFATA within the timeline required. There were 7 subawards not report representing $2,417,617 in total. Cause/ Effect - The County did no have internal controls in place to ensure accurate and timely subaward information is reported to the FSRS. Questioned Costs- None Auditor's Recommendation - We recommend that the County have policies in place to ensure information si report to the FSRS as required by FFATA. Management Response - See Corrective Action Plan Letter
Material Weakness- Internal Controls over Reporting and Noncompliance Department of Housing and Urban Development - Direct Program - CDBG Entitlement Grants Cluster-ALN 14.218 - Program Year 2023 Criteria- 2 CFR section 200.303 - Internal Controls of the Uniform Guidance states that the non-federal entity must (a) establish and maintain effective internal controls over federal award that provides reasonable assurance that the non-federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in "Standards in Internal Control in the Federal Government" issued by the Comptroller General of the United States of the "Internal Control by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)". 2 CFR Part 170 requires non-federal entities making first-tier subawards of federal funding to comply with the reporting requirements of the Federal Funding Accountability and Transparency Act of 2006 (FFATA) (Public Law 109-282), as amended by section 6202 of Public Law 110-252. Compliance with FFATA requires prime recipients, to report certain information about subawards to the FFATA Subaward Reporting System (FSRS) by the end of the month, plus 30 days, in which the award is made. Condition- The County did not report required information about subawards made under Assistance Listing No. 14.218 to the FSRS as required by FFATA within the timeline required. There were 7 subawards not report representing $2,417,617 in total. Cause/ Effect - The County did no have internal controls in place to ensure accurate and timely subaward information is reported to the FSRS. Questioned Costs- None Auditor's Recommendation - We recommend that the County have policies in place to ensure information si report to the FSRS as required by FFATA. Management Response - See Corrective Action Plan Letter
Material Weakness- Internal Controls over Reporting and Noncompliance Department of Housing and Urban Development - Direct Program - CDBG Entitlement Grants Cluster-ALN 14.218 - Program Year 2023 Criteria- 2 CFR section 200.303 - Internal Controls of the Uniform Guidance states that the non-federal entity must (a) establish and maintain effective internal controls over federal award that provides reasonable assurance that the non-federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in "Standards in Internal Control in the Federal Government" issued by the Comptroller General of the United States of the "Internal Control by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)". 2 CFR Part 170 requires non-federal entities making first-tier subawards of federal funding to comply with the reporting requirements of the Federal Funding Accountability and Transparency Act of 2006 (FFATA) (Public Law 109-282), as amended by section 6202 of Public Law 110-252. Compliance with FFATA requires prime recipients, to report certain information about subawards to the FFATA Subaward Reporting System (FSRS) by the end of the month, plus 30 days, in which the award is made. Condition- The County did not report required information about subawards made under Assistance Listing No. 14.218 to the FSRS as required by FFATA within the timeline required. There were 7 subawards not report representing $2,417,617 in total. Cause/ Effect - The County did no have internal controls in place to ensure accurate and timely subaward information is reported to the FSRS. Questioned Costs- None Auditor's Recommendation - We recommend that the County have policies in place to ensure information si report to the FSRS as required by FFATA. Management Response - See Corrective Action Plan Letter
Material Weakness- Internal Controls over Reporting and Noncompliance Department of Housing and Urban Development - Direct Program - CDBG Entitlement Grants Cluster-ALN 14.218 - Program Year 2023 Criteria- 2 CFR section 200.303 - Internal Controls of the Uniform Guidance states that the non-federal entity must (a) establish and maintain effective internal controls over federal award that provides reasonable assurance that the non-federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in "Standards in Internal Control in the Federal Government" issued by the Comptroller General of the United States of the "Internal Control by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)". 2 CFR Part 170 requires non-federal entities making first-tier subawards of federal funding to comply with the reporting requirements of the Federal Funding Accountability and Transparency Act of 2006 (FFATA) (Public Law 109-282), as amended by section 6202 of Public Law 110-252. Compliance with FFATA requires prime recipients, to report certain information about subawards to the FFATA Subaward Reporting System (FSRS) by the end of the month, plus 30 days, in which the award is made. Condition- The County did not report required information about subawards made under Assistance Listing No. 14.218 to the FSRS as required by FFATA within the timeline required. There were 7 subawards not report representing $2,417,617 in total. Cause/ Effect - The County did no have internal controls in place to ensure accurate and timely subaward information is reported to the FSRS. Questioned Costs- None Auditor's Recommendation - We recommend that the County have policies in place to ensure information si report to the FSRS as required by FFATA. Management Response - See Corrective Action Plan Letter
Department of Health and Human Services Federal Assistance Listing #93.498 COVID‐19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 4 TIN #860554593 Reporting Material Weakness in Internal Control Over Compliance and Material Noncompliance Criteria ‐ 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The Organization selected Option iii to calculate lost revenue, which consists of utilizing an alternative reasonable method. Condition ‐ The Organization selected option iii to calculate lost revenue using budgeted gross revenues to actual gross revenues. The Organization’s HHS Period 4 Report included lost revenues for three quarters that did not agree to the supporting calculation of lost revenues. Cause ‐ The budgeted amounts were updated after the HHH Period 4 Report was submitted. Those changes decreased the budgeted amounts for three quarters in 2022 resulting in lost revenues being under‐reported by $278,644. Effect ‐ The Organization understated the amount of lost revenues claimed in the HHS Period 4 Report by $278,446. While the Organization had an error in the total amount of lost revenues reported, the Organization has unused lost revenues of $4,563,025. Should the lost revenue reported by the Organization be corrected, the unused lost revenues would be $4,841,669. Questioned Costs ‐ None reported. Context ‐ Lost revenue was tested for all twelve quarters included in the HHS Period 4 Report. Three of the quarters had lost revenues which were reported incorrectly (Quarters 1, 2, and 3 in 2022). Repeat Finding from Prior Years ‐ No Recommendation ‐ We recommend that the Organization enhance internal control policies over the budget to ensure that the lost revenue calculation is not changed after submission and follows the Option iii methodology utilized to calculate lost revenues. Views of Responsible Officials ‐ Management agrees with the finding.
Condition: Numerous data entry errors occurred during the year where incorrect check numbers were entered into the accounting system. There were also multiple gaps in sequence in the check register. This should have been discovered during the bank reconciliation process (review of canceled check images) but was not. Bank statements were not reconciled correctly on a timely basis, and lists of outstanding checks were not included with the approved bank reconciliations. Criteria: The Code of Federal Regulations (CFR) § 200.303 requires the organization to establish and maintain effective internal control that provides reasonable assurance that the organization is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Cause: The Organization experienced significant staff turnover during the year. Effect: Internal controls over operating cash were deficient. Bank reconciliations had to be reperformed after year-end by the new Accountant. Recommendation: Bank reconciliations should include details (list of outstanding items) and be reviewed on a monthly basis. Any gaps in check sequence, stale-dated items and other unusual items should be followed up on and investigated. Bank reconciliations should be done in a timely manner (generally within 30-45 days after month-end). Views of Responsible Officials: Management concurs. See Corrective Action Plan.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Federal Assistance Listing Number: 93.600 Award Period: June 1, 2022 to May 31, 2023; June 1, 2023 to May 31, 2024; August 1, 2022 to July 31, 2023; April 1, 2021 to March 31, 2023; and August 1, 2023 to July 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years Under 2CFR section 200.303 A nonfederal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the nonfederal 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: During our testing, we noted the Organization's last documented inventory count was taken in 2019. Questioned Costs: N/A Context: The last physical inventory count was taken in 2019. One was in the process of being done in 2023 but was not finished in time for the audit. Cause: The Organization did not take a physical inventory count within the past two years and reconcile to the accounting records; however, they do have procedures in place to monitor the inventory in other ways. The organizations inventory that is building related (renovations, upkeep, equipment), they are constantly discussing with their facilities person regarding buildings, fencing, turfing and playground inventory that required repairs and maintenance. Office inventory is within their site at either of their locations where they are at least several times a year to view and inventory what is there. Management meets throughout the year regarding inventory and budgeted items needed. Effect: Potential for missing, old, or out of use property Repeat Finding: Yes Recommendation: The Organization should ensure a physical inventory count is taken and reconciled to their records at least once every two years. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Federal Assistance Listing Number: 93.600 Award Period: June 1, 2022 to May 31, 2023; June 1, 2023 to May 31, 2024; August 1, 2022 to July 31, 2023; April 1, 2021 to March 31, 2023; and August 1, 2023 to July 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years Under 2CFR section 200.303 A nonfederal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the nonfederal 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: During our testing, we noted the Organization's last documented inventory count was taken in 2019. Questioned Costs: N/A Context: The last physical inventory count was taken in 2019. One was in the process of being done in 2023 but was not finished in time for the audit. Cause: The Organization did not take a physical inventory count within the past two years and reconcile to the accounting records; however, they do have procedures in place to monitor the inventory in other ways. The organizations inventory that is building related (renovations, upkeep, equipment), they are constantly discussing with their facilities person regarding buildings, fencing, turfing and playground inventory that required repairs and maintenance. Office inventory is within their site at either of their locations where they are at least several times a year to view and inventory what is there. Management meets throughout the year regarding inventory and budgeted items needed. Effect: Potential for missing, old, or out of use property Repeat Finding: Yes Recommendation: The Organization should ensure a physical inventory count is taken and reconciled to their records at least once every two years. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Federal Assistance Listing Number: 93.600 Award Period: June 1, 2022 to May 31, 2023; June 1, 2023 to May 31, 2024; August 1, 2022 to July 31, 2023; April 1, 2021 to March 31, 2023; and August 1, 2023 to July 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years Under 2CFR section 200.303 A nonfederal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the nonfederal 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: During our testing, we noted the Organization's last documented inventory count was taken in 2019. Questioned Costs: N/A Context: The last physical inventory count was taken in 2019. One was in the process of being done in 2023 but was not finished in time for the audit. Cause: The Organization did not take a physical inventory count within the past two years and reconcile to the accounting records; however, they do have procedures in place to monitor the inventory in other ways. The organizations inventory that is building related (renovations, upkeep, equipment), they are constantly discussing with their facilities person regarding buildings, fencing, turfing and playground inventory that required repairs and maintenance. Office inventory is within their site at either of their locations where they are at least several times a year to view and inventory what is there. Management meets throughout the year regarding inventory and budgeted items needed. Effect: Potential for missing, old, or out of use property Repeat Finding: Yes Recommendation: The Organization should ensure a physical inventory count is taken and reconciled to their records at least once every two years. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Federal Assistance Listing Number: 93.600 Award Period: June 1, 2022 to May 31, 2023; June 1, 2023 to May 31, 2024; August 1, 2022 to July 31, 2023; April 1, 2021 to March 31, 2023; and August 1, 2023 to July 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years Under 2CFR section 200.303 A nonfederal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the nonfederal 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: During our testing, we noted the Organization's last documented inventory count was taken in 2019. Questioned Costs: N/A Context: The last physical inventory count was taken in 2019. One was in the process of being done in 2023 but was not finished in time for the audit. Cause: The Organization did not take a physical inventory count within the past two years and reconcile to the accounting records; however, they do have procedures in place to monitor the inventory in other ways. The organizations inventory that is building related (renovations, upkeep, equipment), they are constantly discussing with their facilities person regarding buildings, fencing, turfing and playground inventory that required repairs and maintenance. Office inventory is within their site at either of their locations where they are at least several times a year to view and inventory what is there. Management meets throughout the year regarding inventory and budgeted items needed. Effect: Potential for missing, old, or out of use property Repeat Finding: Yes Recommendation: The Organization should ensure a physical inventory count is taken and reconciled to their records at least once every two years. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Federal Assistance Listing Number: 93.600 Award Period: June 1, 2022 to May 31, 2023; June 1, 2023 to May 31, 2024; August 1, 2022 to July 31, 2023; April 1, 2021 to March 31, 2023; and August 1, 2023 to July 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years Under 2CFR section 200.303 A nonfederal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the nonfederal 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: During our testing, we noted the Organization's last documented inventory count was taken in 2019. Questioned Costs: N/A Context: The last physical inventory count was taken in 2019. One was in the process of being done in 2023 but was not finished in time for the audit. Cause: The Organization did not take a physical inventory count within the past two years and reconcile to the accounting records; however, they do have procedures in place to monitor the inventory in other ways. The organizations inventory that is building related (renovations, upkeep, equipment), they are constantly discussing with their facilities person regarding buildings, fencing, turfing and playground inventory that required repairs and maintenance. Office inventory is within their site at either of their locations where they are at least several times a year to view and inventory what is there. Management meets throughout the year regarding inventory and budgeted items needed. Effect: Potential for missing, old, or out of use property Repeat Finding: Yes Recommendation: The Organization should ensure a physical inventory count is taken and reconciled to their records at least once every two years. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Federal Assistance Listing Number: 93.600 Award Period: June 1, 2022 to May 31, 2023; June 1, 2023 to May 31, 2024; August 1, 2022 to July 31, 2023; April 1, 2021 to March 31, 2023; and August 1, 2023 to July 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years Under 2CFR section 200.303 A nonfederal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the nonfederal 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: During our testing, we noted the Organization's last documented inventory count was taken in 2019. Questioned Costs: N/A Context: The last physical inventory count was taken in 2019. One was in the process of being done in 2023 but was not finished in time for the audit. Cause: The Organization did not take a physical inventory count within the past two years and reconcile to the accounting records; however, they do have procedures in place to monitor the inventory in other ways. The organizations inventory that is building related (renovations, upkeep, equipment), they are constantly discussing with their facilities person regarding buildings, fencing, turfing and playground inventory that required repairs and maintenance. Office inventory is within their site at either of their locations where they are at least several times a year to view and inventory what is there. Management meets throughout the year regarding inventory and budgeted items needed. Effect: Potential for missing, old, or out of use property Repeat Finding: Yes Recommendation: The Organization should ensure a physical inventory count is taken and reconciled to their records at least once every two years. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Finding 2023‐001: Significant Deficiency, Internal Control Over Compliance Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.498 – COVID‐19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Award Year: 2021 Federal Award Identification: PRF 20210001 Pass‐Through Entity: N/A Criteria: Per 2 CFR 200.303 and 2 CFR 200.430(i), a non‐federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award and establishes the standard for documentation of personnel expenses. Condition: Payroll expenses are an allowed expense according to the guidance and FAQs generated by HRSA. The Medical Center should have controls in place whereby all expenses are reviewed prior to submission to ensure the expense is for the proper purpose. Cause: There was no policy implemented to require the documented approval of a corrected time card. Effect: For one of twenty‐five payroll expenses selected, there was no approval of a corrected time card prior to the payroll being submitted. Questioned Costs: $‐0‐ Perspective: The payroll expense was an allowable costs under the guidance issue by HHS. This finding does not generate any questioned costs or unallowable costs being used in the PRF submission. Recommendation: We recommend the Medical Center implement a process whereby all timesheets (original and corrected) have to be approved by a supervisor prior to payroll being generated and that approval is documented and maintained. Views of Responsible Officials and Planned Corrective Action: Management concurs with auditors’ finding and recommendation. Management’s Response: See attached corrective action plan.
U.S. Department of Agriculture Federal Assistance Listing #10.766 Community Facilities Loans and Grants Cluster Applicable Federal Award Number – Direct Loan and Guaranteed Loan Special Tests and Provisions Significant Deficiency in Internal Control Over Compliance and Noncompliance Not Considered Material Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Medical Center was required to establish reserve accounts with deposits equal to 10% of the annual debt service requirement on the direct loan and guaranteed loan. The Medical Center did not establish these accounts, which were expected to total $48,386, based on three months of required deposits, during 2023. Cause: This deficiency is due to a misunderstanding of establishing reserve accounts as Salina Regional Health Center is the centralized cash management agent for the Medical Center. Effect: The Medical Center was not in compliance with the terms of the loan agreements related to the reserve funds. Questioned Costs: None. Context: Sampling was not used. Repeat Finding from Prior Years: No. Recommendation: We recommend that management create the appropriate reserve accounts, as required under the loan agreements. We recommend management implement a control process to ensure the monthly deposits are made as required, until the accounts are fully funded. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S Department of Agriculture Federal Program Name: Food Distribution Cluster Assistance Listing Number: 10.568, 10.569 Federal Award Identification Number and Year: N/A; 2023 Pass-Through Agency: Indiana Department of Health Pass-Through Number(s): 65260, 68485 Award Period: October 01, 2022 - September 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.303, "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Gleaners did not maintain documentation of control sign-offs on all receipts during the year. Questioned costs: None. Context: Gleaners' documentation for receipt of goods did not include the required control sign-offs on 5 of 40 receipts tested under the TEFAP program. Cause: Gleaners did not maintain documentation of control sign-offs on receipts during the year due to staffing shortages and turn-over. Effect: Without documentation of the completed control, there is the risk that Gleaners would have receipted items incorrectly and/or inaccurately under the program. Repeat Finding: No Recommendation: We recommend that Gleaners review its process and procedures to ensure all control sign-offs are maintained on receipts. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S Department of Agriculture Federal Program Name: Food Distribution Cluster Assistance Listing Number: 10.568, 10.569 Federal Award Identification Number and Year: N/A; 2023 Pass-Through Agency: Indiana Department of Health Pass-Through Number(s): 65260, 68485 Award Period: October 01, 2022 - September 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.303, "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Gleaners did not maintain documentation of control sign-offs on all receipts during the year. Questioned costs: None. Context: Gleaners' documentation for receipt of goods did not include the required control sign-offs on 5 of 40 receipts tested under the TEFAP program. Cause: Gleaners did not maintain documentation of control sign-offs on receipts during the year due to staffing shortages and turn-over. Effect: Without documentation of the completed control, there is the risk that Gleaners would have receipted items incorrectly and/or inaccurately under the program. Repeat Finding: No Recommendation: We recommend that Gleaners review its process and procedures to ensure all control sign-offs are maintained on receipts. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S Department of Agriculture Federal Program Name: Food Distribution Cluster Assistance Listing Number: 10.568, 10.569 Federal Award Identification Number and Year: N/A; 2023 Pass-Through Agency: Indiana Department of Health Pass-Through Number(s): 65260, 68485 Award Period: October 01, 2022 - September 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.303, "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Gleaners did not maintain documentation of control sign-offs on all receipts during the year. Questioned costs: None. Context: Gleaners' documentation for receipt of goods did not include the required control sign-offs on 5 of 40 receipts tested under the TEFAP program. Cause: Gleaners did not maintain documentation of control sign-offs on receipts during the year due to staffing shortages and turn-over. Effect: Without documentation of the completed control, there is the risk that Gleaners would have receipted items incorrectly and/or inaccurately under the program. Repeat Finding: No Recommendation: We recommend that Gleaners review its process and procedures to ensure all control sign-offs are maintained on receipts. Views of responsible officials: There is no disagreement with the audit finding.
Lack of Internal Control over Reporting Federal Agency: U.S. Department of Homeland Security, U.S. Department of Commerce, U.S. Department of the Interior. Federal Program: Research and Development Cluster ALN: 97.OPA, 11.427, 11.472, 15.654 and 15.945 Award Numbers: Coast Guard Authorization Act of 1996, 23-10-01, 22-10-13, 23-10-03, 20-10-04, NA20NMF4270158, NA17NMF4720018, NA22NMF4720078, NA22NMF4720201, NA19NMF4720069, P22AC01027 Award Years: None, 2023, 2022, 2023, 2020, 2020, 2017, 2022, 2022, 2019, and 2022, respectively Type of Finding: Significant deficiency in internal control over compliance and noncompliance. Criteria: Title 2 CFR 200.303 requires the Center to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Center is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the grant awards. Title 2 CFR 170 states federal award recipients are required to report each subaward that obligates $30,000 or more in federal funds. This information must be reported no later than the end of the month following the month in which the obligation was made and include information about each obligating action in accordance with submission instructions. Condition and Context: FY23 Federal Funding Accountability and Transparency Act (FFATA) subaward reporting for Long-Term Monitoring & Herring Research & Monitoring, Gulf Watch Alaska Research and Monitoring, and Sustainable Mariculture Development Programs did not occur for subawards. FFATA requires information on federal awards to be made available to the public via a single searchable website (www.usaspending.gov). The FFATA Subaward Reporting System (FSRS) is the reporting tool federal awardees use to capture and report subaward regarding first-tier subawards. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 9 9 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,190,391 $2,190,391 $0 $0 $0 Cause: Lack of internal control over reporting. Effect: Failure to comply with FFATA reporting requirements reduces transparency, impairs decision-making, and may potentially jeopardize future federal funding. Questioned Costs: None. Repeat Finding: This is not a repeat finding. We believe this to be a systemic issue. Recommendation: The Center should develop FFATA reporting policies and procedures to submit subaward award information through FSRS to ensure compliance with FFATA requirements. Management’s Response: Management agrees with this finding. See Corrective Action Plan. .
Lack of Internal Control over Reporting Federal Agency: U.S. Department of Homeland Security, U.S. Department of Commerce, U.S. Department of the Interior. Federal Program: Research and Development Cluster ALN: 97.OPA, 11.427, 11.472, 15.654 and 15.945 Award Numbers: Coast Guard Authorization Act of 1996, 23-10-01, 22-10-13, 23-10-03, 20-10-04, NA20NMF4270158, NA17NMF4720018, NA22NMF4720078, NA22NMF4720201, NA19NMF4720069, P22AC01027 Award Years: None, 2023, 2022, 2023, 2020, 2020, 2017, 2022, 2022, 2019, and 2022, respectively Type of Finding: Significant deficiency in internal control over compliance and noncompliance. Criteria: Title 2 CFR 200.303 requires the Center to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Center is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the grant awards. Title 2 CFR 170 states federal award recipients are required to report each subaward that obligates $30,000 or more in federal funds. This information must be reported no later than the end of the month following the month in which the obligation was made and include information about each obligating action in accordance with submission instructions. Condition and Context: FY23 Federal Funding Accountability and Transparency Act (FFATA) subaward reporting for Long-Term Monitoring & Herring Research & Monitoring, Gulf Watch Alaska Research and Monitoring, and Sustainable Mariculture Development Programs did not occur for subawards. FFATA requires information on federal awards to be made available to the public via a single searchable website (www.usaspending.gov). The FFATA Subaward Reporting System (FSRS) is the reporting tool federal awardees use to capture and report subaward regarding first-tier subawards. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 9 9 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,190,391 $2,190,391 $0 $0 $0 Cause: Lack of internal control over reporting. Effect: Failure to comply with FFATA reporting requirements reduces transparency, impairs decision-making, and may potentially jeopardize future federal funding. Questioned Costs: None. Repeat Finding: This is not a repeat finding. We believe this to be a systemic issue. Recommendation: The Center should develop FFATA reporting policies and procedures to submit subaward award information through FSRS to ensure compliance with FFATA requirements. Management’s Response: Management agrees with this finding. See Corrective Action Plan. .
Lack of Internal Control over Reporting Federal Agency: U.S. Department of Homeland Security, U.S. Department of Commerce, U.S. Department of the Interior. Federal Program: Research and Development Cluster ALN: 97.OPA, 11.427, 11.472, 15.654 and 15.945 Award Numbers: Coast Guard Authorization Act of 1996, 23-10-01, 22-10-13, 23-10-03, 20-10-04, NA20NMF4270158, NA17NMF4720018, NA22NMF4720078, NA22NMF4720201, NA19NMF4720069, P22AC01027 Award Years: None, 2023, 2022, 2023, 2020, 2020, 2017, 2022, 2022, 2019, and 2022, respectively Type of Finding: Significant deficiency in internal control over compliance and noncompliance. Criteria: Title 2 CFR 200.303 requires the Center to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Center is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the grant awards. Title 2 CFR 170 states federal award recipients are required to report each subaward that obligates $30,000 or more in federal funds. This information must be reported no later than the end of the month following the month in which the obligation was made and include information about each obligating action in accordance with submission instructions. Condition and Context: FY23 Federal Funding Accountability and Transparency Act (FFATA) subaward reporting for Long-Term Monitoring & Herring Research & Monitoring, Gulf Watch Alaska Research and Monitoring, and Sustainable Mariculture Development Programs did not occur for subawards. FFATA requires information on federal awards to be made available to the public via a single searchable website (www.usaspending.gov). The FFATA Subaward Reporting System (FSRS) is the reporting tool federal awardees use to capture and report subaward regarding first-tier subawards. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 9 9 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,190,391 $2,190,391 $0 $0 $0 Cause: Lack of internal control over reporting. Effect: Failure to comply with FFATA reporting requirements reduces transparency, impairs decision-making, and may potentially jeopardize future federal funding. Questioned Costs: None. Repeat Finding: This is not a repeat finding. We believe this to be a systemic issue. Recommendation: The Center should develop FFATA reporting policies and procedures to submit subaward award information through FSRS to ensure compliance with FFATA requirements. Management’s Response: Management agrees with this finding. See Corrective Action Plan. .
Lack of Internal Control over Reporting Federal Agency: U.S. Department of Homeland Security, U.S. Department of Commerce, U.S. Department of the Interior. Federal Program: Research and Development Cluster ALN: 97.OPA, 11.427, 11.472, 15.654 and 15.945 Award Numbers: Coast Guard Authorization Act of 1996, 23-10-01, 22-10-13, 23-10-03, 20-10-04, NA20NMF4270158, NA17NMF4720018, NA22NMF4720078, NA22NMF4720201, NA19NMF4720069, P22AC01027 Award Years: None, 2023, 2022, 2023, 2020, 2020, 2017, 2022, 2022, 2019, and 2022, respectively Type of Finding: Significant deficiency in internal control over compliance and noncompliance. Criteria: Title 2 CFR 200.303 requires the Center to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Center is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the grant awards. Title 2 CFR 170 states federal award recipients are required to report each subaward that obligates $30,000 or more in federal funds. This information must be reported no later than the end of the month following the month in which the obligation was made and include information about each obligating action in accordance with submission instructions. Condition and Context: FY23 Federal Funding Accountability and Transparency Act (FFATA) subaward reporting for Long-Term Monitoring & Herring Research & Monitoring, Gulf Watch Alaska Research and Monitoring, and Sustainable Mariculture Development Programs did not occur for subawards. FFATA requires information on federal awards to be made available to the public via a single searchable website (www.usaspending.gov). The FFATA Subaward Reporting System (FSRS) is the reporting tool federal awardees use to capture and report subaward regarding first-tier subawards. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 9 9 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,190,391 $2,190,391 $0 $0 $0 Cause: Lack of internal control over reporting. Effect: Failure to comply with FFATA reporting requirements reduces transparency, impairs decision-making, and may potentially jeopardize future federal funding. Questioned Costs: None. Repeat Finding: This is not a repeat finding. We believe this to be a systemic issue. Recommendation: The Center should develop FFATA reporting policies and procedures to submit subaward award information through FSRS to ensure compliance with FFATA requirements. Management’s Response: Management agrees with this finding. See Corrective Action Plan. .
Lack of Internal Control over Reporting Federal Agency: U.S. Department of Homeland Security, U.S. Department of Commerce, U.S. Department of the Interior. Federal Program: Research and Development Cluster ALN: 97.OPA, 11.427, 11.472, 15.654 and 15.945 Award Numbers: Coast Guard Authorization Act of 1996, 23-10-01, 22-10-13, 23-10-03, 20-10-04, NA20NMF4270158, NA17NMF4720018, NA22NMF4720078, NA22NMF4720201, NA19NMF4720069, P22AC01027 Award Years: None, 2023, 2022, 2023, 2020, 2020, 2017, 2022, 2022, 2019, and 2022, respectively Type of Finding: Significant deficiency in internal control over compliance and noncompliance. Criteria: Title 2 CFR 200.303 requires the Center to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Center is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the grant awards. Title 2 CFR 170 states federal award recipients are required to report each subaward that obligates $30,000 or more in federal funds. This information must be reported no later than the end of the month following the month in which the obligation was made and include information about each obligating action in accordance with submission instructions. Condition and Context: FY23 Federal Funding Accountability and Transparency Act (FFATA) subaward reporting for Long-Term Monitoring & Herring Research & Monitoring, Gulf Watch Alaska Research and Monitoring, and Sustainable Mariculture Development Programs did not occur for subawards. FFATA requires information on federal awards to be made available to the public via a single searchable website (www.usaspending.gov). The FFATA Subaward Reporting System (FSRS) is the reporting tool federal awardees use to capture and report subaward regarding first-tier subawards. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 9 9 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,190,391 $2,190,391 $0 $0 $0 Cause: Lack of internal control over reporting. Effect: Failure to comply with FFATA reporting requirements reduces transparency, impairs decision-making, and may potentially jeopardize future federal funding. Questioned Costs: None. Repeat Finding: This is not a repeat finding. We believe this to be a systemic issue. Recommendation: The Center should develop FFATA reporting policies and procedures to submit subaward award information through FSRS to ensure compliance with FFATA requirements. Management’s Response: Management agrees with this finding. See Corrective Action Plan. .
Lack of Internal Control over Reporting Federal Agency: U.S. Department of Homeland Security, U.S. Department of Commerce, U.S. Department of the Interior. Federal Program: Research and Development Cluster ALN: 97.OPA, 11.427, 11.472, 15.654 and 15.945 Award Numbers: Coast Guard Authorization Act of 1996, 23-10-01, 22-10-13, 23-10-03, 20-10-04, NA20NMF4270158, NA17NMF4720018, NA22NMF4720078, NA22NMF4720201, NA19NMF4720069, P22AC01027 Award Years: None, 2023, 2022, 2023, 2020, 2020, 2017, 2022, 2022, 2019, and 2022, respectively Type of Finding: Significant deficiency in internal control over compliance and noncompliance. Criteria: Title 2 CFR 200.303 requires the Center to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Center is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the grant awards. Title 2 CFR 170 states federal award recipients are required to report each subaward that obligates $30,000 or more in federal funds. This information must be reported no later than the end of the month following the month in which the obligation was made and include information about each obligating action in accordance with submission instructions. Condition and Context: FY23 Federal Funding Accountability and Transparency Act (FFATA) subaward reporting for Long-Term Monitoring & Herring Research & Monitoring, Gulf Watch Alaska Research and Monitoring, and Sustainable Mariculture Development Programs did not occur for subawards. FFATA requires information on federal awards to be made available to the public via a single searchable website (www.usaspending.gov). The FFATA Subaward Reporting System (FSRS) is the reporting tool federal awardees use to capture and report subaward regarding first-tier subawards. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 9 9 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,190,391 $2,190,391 $0 $0 $0 Cause: Lack of internal control over reporting. Effect: Failure to comply with FFATA reporting requirements reduces transparency, impairs decision-making, and may potentially jeopardize future federal funding. Questioned Costs: None. Repeat Finding: This is not a repeat finding. We believe this to be a systemic issue. Recommendation: The Center should develop FFATA reporting policies and procedures to submit subaward award information through FSRS to ensure compliance with FFATA requirements. Management’s Response: Management agrees with this finding. See Corrective Action Plan. .
Lack of Internal Control over Reporting Federal Agency: U.S. Department of Homeland Security, U.S. Department of Commerce, U.S. Department of the Interior. Federal Program: Research and Development Cluster ALN: 97.OPA, 11.427, 11.472, 15.654 and 15.945 Award Numbers: Coast Guard Authorization Act of 1996, 23-10-01, 22-10-13, 23-10-03, 20-10-04, NA20NMF4270158, NA17NMF4720018, NA22NMF4720078, NA22NMF4720201, NA19NMF4720069, P22AC01027 Award Years: None, 2023, 2022, 2023, 2020, 2020, 2017, 2022, 2022, 2019, and 2022, respectively Type of Finding: Significant deficiency in internal control over compliance and noncompliance. Criteria: Title 2 CFR 200.303 requires the Center to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Center is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the grant awards. Title 2 CFR 170 states federal award recipients are required to report each subaward that obligates $30,000 or more in federal funds. This information must be reported no later than the end of the month following the month in which the obligation was made and include information about each obligating action in accordance with submission instructions. Condition and Context: FY23 Federal Funding Accountability and Transparency Act (FFATA) subaward reporting for Long-Term Monitoring & Herring Research & Monitoring, Gulf Watch Alaska Research and Monitoring, and Sustainable Mariculture Development Programs did not occur for subawards. FFATA requires information on federal awards to be made available to the public via a single searchable website (www.usaspending.gov). The FFATA Subaward Reporting System (FSRS) is the reporting tool federal awardees use to capture and report subaward regarding first-tier subawards. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 9 9 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,190,391 $2,190,391 $0 $0 $0 Cause: Lack of internal control over reporting. Effect: Failure to comply with FFATA reporting requirements reduces transparency, impairs decision-making, and may potentially jeopardize future federal funding. Questioned Costs: None. Repeat Finding: This is not a repeat finding. We believe this to be a systemic issue. Recommendation: The Center should develop FFATA reporting policies and procedures to submit subaward award information through FSRS to ensure compliance with FFATA requirements. Management’s Response: Management agrees with this finding. See Corrective Action Plan. .
Lack of Internal Control over Reporting Federal Agency: U.S. Department of Homeland Security, U.S. Department of Commerce, U.S. Department of the Interior. Federal Program: Research and Development Cluster ALN: 97.OPA, 11.427, 11.472, 15.654 and 15.945 Award Numbers: Coast Guard Authorization Act of 1996, 23-10-01, 22-10-13, 23-10-03, 20-10-04, NA20NMF4270158, NA17NMF4720018, NA22NMF4720078, NA22NMF4720201, NA19NMF4720069, P22AC01027 Award Years: None, 2023, 2022, 2023, 2020, 2020, 2017, 2022, 2022, 2019, and 2022, respectively Type of Finding: Significant deficiency in internal control over compliance and noncompliance. Criteria: Title 2 CFR 200.303 requires the Center to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Center is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the grant awards. Title 2 CFR 170 states federal award recipients are required to report each subaward that obligates $30,000 or more in federal funds. This information must be reported no later than the end of the month following the month in which the obligation was made and include information about each obligating action in accordance with submission instructions. Condition and Context: FY23 Federal Funding Accountability and Transparency Act (FFATA) subaward reporting for Long-Term Monitoring & Herring Research & Monitoring, Gulf Watch Alaska Research and Monitoring, and Sustainable Mariculture Development Programs did not occur for subawards. FFATA requires information on federal awards to be made available to the public via a single searchable website (www.usaspending.gov). The FFATA Subaward Reporting System (FSRS) is the reporting tool federal awardees use to capture and report subaward regarding first-tier subawards. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 9 9 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,190,391 $2,190,391 $0 $0 $0 Cause: Lack of internal control over reporting. Effect: Failure to comply with FFATA reporting requirements reduces transparency, impairs decision-making, and may potentially jeopardize future federal funding. Questioned Costs: None. Repeat Finding: This is not a repeat finding. We believe this to be a systemic issue. Recommendation: The Center should develop FFATA reporting policies and procedures to submit subaward award information through FSRS to ensure compliance with FFATA requirements. Management’s Response: Management agrees with this finding. See Corrective Action Plan. .
Lack of Internal Control over Reporting Federal Agency: U.S. Department of Homeland Security, U.S. Department of Commerce, U.S. Department of the Interior. Federal Program: Research and Development Cluster ALN: 97.OPA, 11.427, 11.472, 15.654 and 15.945 Award Numbers: Coast Guard Authorization Act of 1996, 23-10-01, 22-10-13, 23-10-03, 20-10-04, NA20NMF4270158, NA17NMF4720018, NA22NMF4720078, NA22NMF4720201, NA19NMF4720069, P22AC01027 Award Years: None, 2023, 2022, 2023, 2020, 2020, 2017, 2022, 2022, 2019, and 2022, respectively Type of Finding: Significant deficiency in internal control over compliance and noncompliance. Criteria: Title 2 CFR 200.303 requires the Center to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Center is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the grant awards. Title 2 CFR 170 states federal award recipients are required to report each subaward that obligates $30,000 or more in federal funds. This information must be reported no later than the end of the month following the month in which the obligation was made and include information about each obligating action in accordance with submission instructions. Condition and Context: FY23 Federal Funding Accountability and Transparency Act (FFATA) subaward reporting for Long-Term Monitoring & Herring Research & Monitoring, Gulf Watch Alaska Research and Monitoring, and Sustainable Mariculture Development Programs did not occur for subawards. FFATA requires information on federal awards to be made available to the public via a single searchable website (www.usaspending.gov). The FFATA Subaward Reporting System (FSRS) is the reporting tool federal awardees use to capture and report subaward regarding first-tier subawards. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 9 9 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,190,391 $2,190,391 $0 $0 $0 Cause: Lack of internal control over reporting. Effect: Failure to comply with FFATA reporting requirements reduces transparency, impairs decision-making, and may potentially jeopardize future federal funding. Questioned Costs: None. Repeat Finding: This is not a repeat finding. We believe this to be a systemic issue. Recommendation: The Center should develop FFATA reporting policies and procedures to submit subaward award information through FSRS to ensure compliance with FFATA requirements. Management’s Response: Management agrees with this finding. See Corrective Action Plan. .
Lack of Internal Control over Reporting Federal Agency: U.S. Department of Homeland Security, U.S. Department of Commerce, U.S. Department of the Interior. Federal Program: Research and Development Cluster ALN: 97.OPA, 11.427, 11.472, 15.654 and 15.945 Award Numbers: Coast Guard Authorization Act of 1996, 23-10-01, 22-10-13, 23-10-03, 20-10-04, NA20NMF4270158, NA17NMF4720018, NA22NMF4720078, NA22NMF4720201, NA19NMF4720069, P22AC01027 Award Years: None, 2023, 2022, 2023, 2020, 2020, 2017, 2022, 2022, 2019, and 2022, respectively Type of Finding: Significant deficiency in internal control over compliance and noncompliance. Criteria: Title 2 CFR 200.303 requires the Center to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Center is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the grant awards. Title 2 CFR 170 states federal award recipients are required to report each subaward that obligates $30,000 or more in federal funds. This information must be reported no later than the end of the month following the month in which the obligation was made and include information about each obligating action in accordance with submission instructions. Condition and Context: FY23 Federal Funding Accountability and Transparency Act (FFATA) subaward reporting for Long-Term Monitoring & Herring Research & Monitoring, Gulf Watch Alaska Research and Monitoring, and Sustainable Mariculture Development Programs did not occur for subawards. FFATA requires information on federal awards to be made available to the public via a single searchable website (www.usaspending.gov). The FFATA Subaward Reporting System (FSRS) is the reporting tool federal awardees use to capture and report subaward regarding first-tier subawards. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 9 9 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,190,391 $2,190,391 $0 $0 $0 Cause: Lack of internal control over reporting. Effect: Failure to comply with FFATA reporting requirements reduces transparency, impairs decision-making, and may potentially jeopardize future federal funding. Questioned Costs: None. Repeat Finding: This is not a repeat finding. We believe this to be a systemic issue. Recommendation: The Center should develop FFATA reporting policies and procedures to submit subaward award information through FSRS to ensure compliance with FFATA requirements. Management’s Response: Management agrees with this finding. See Corrective Action Plan. .
Lack of Internal Control over Reporting Federal Agency: U.S. Department of Homeland Security, U.S. Department of Commerce, U.S. Department of the Interior. Federal Program: Research and Development Cluster ALN: 97.OPA, 11.427, 11.472, 15.654 and 15.945 Award Numbers: Coast Guard Authorization Act of 1996, 23-10-01, 22-10-13, 23-10-03, 20-10-04, NA20NMF4270158, NA17NMF4720018, NA22NMF4720078, NA22NMF4720201, NA19NMF4720069, P22AC01027 Award Years: None, 2023, 2022, 2023, 2020, 2020, 2017, 2022, 2022, 2019, and 2022, respectively Type of Finding: Significant deficiency in internal control over compliance and noncompliance. Criteria: Title 2 CFR 200.303 requires the Center to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Center is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the grant awards. Title 2 CFR 170 states federal award recipients are required to report each subaward that obligates $30,000 or more in federal funds. This information must be reported no later than the end of the month following the month in which the obligation was made and include information about each obligating action in accordance with submission instructions. Condition and Context: FY23 Federal Funding Accountability and Transparency Act (FFATA) subaward reporting for Long-Term Monitoring & Herring Research & Monitoring, Gulf Watch Alaska Research and Monitoring, and Sustainable Mariculture Development Programs did not occur for subawards. FFATA requires information on federal awards to be made available to the public via a single searchable website (www.usaspending.gov). The FFATA Subaward Reporting System (FSRS) is the reporting tool federal awardees use to capture and report subaward regarding first-tier subawards. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 9 9 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,190,391 $2,190,391 $0 $0 $0 Cause: Lack of internal control over reporting. Effect: Failure to comply with FFATA reporting requirements reduces transparency, impairs decision-making, and may potentially jeopardize future federal funding. Questioned Costs: None. Repeat Finding: This is not a repeat finding. We believe this to be a systemic issue. Recommendation: The Center should develop FFATA reporting policies and procedures to submit subaward award information through FSRS to ensure compliance with FFATA requirements. Management’s Response: Management agrees with this finding. See Corrective Action Plan. .