Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-003 – Reporting – Federal Accountability and Transparency Act Subaward Reporting System (FFATA) Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of one subawards tested (100%), the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 0 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 75,000 $ 75,000 $ 0 $ 0 $ 0 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-federal entity is required to report each obligating action to FSRS. The action must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment was made. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely. Questioned Costs There were no questioned costs related to reporting. Cause The College misinterpreted the absence of Department of Defense NSA CFDA # / ALN # 12.905 from the Compliance Supplement Compliance Matrix as an indication that this award was not subject to the subrecipient monitoring components of the Uniform Guidance and the Compliance Supplement. Prevalence Frequent. One out of one subawards selected for testing. Effect Without proper program reporting policies and procedures, the submission of late reports is noncompliance with Federal regulation and could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-003 – Reporting – Federal Accountability and Transparency Act Subaward Reporting System (FFATA) Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of one subawards tested (100%), the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 0 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 75,000 $ 75,000 $ 0 $ 0 $ 0 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-federal entity is required to report each obligating action to FSRS. The action must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment was made. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely. Questioned Costs There were no questioned costs related to reporting. Cause The College misinterpreted the absence of Department of Defense NSA CFDA # / ALN # 12.905 from the Compliance Supplement Compliance Matrix as an indication that this award was not subject to the subrecipient monitoring components of the Uniform Guidance and the Compliance Supplement. Prevalence Frequent. One out of one subawards selected for testing. Effect Without proper program reporting policies and procedures, the submission of late reports is noncompliance with Federal regulation and could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-003 – Reporting – Federal Accountability and Transparency Act Subaward Reporting System (FFATA) Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of one subawards tested (100%), the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 0 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 75,000 $ 75,000 $ 0 $ 0 $ 0 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-federal entity is required to report each obligating action to FSRS. The action must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment was made. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely. Questioned Costs There were no questioned costs related to reporting. Cause The College misinterpreted the absence of Department of Defense NSA CFDA # / ALN # 12.905 from the Compliance Supplement Compliance Matrix as an indication that this award was not subject to the subrecipient monitoring components of the Uniform Guidance and the Compliance Supplement. Prevalence Frequent. One out of one subawards selected for testing. Effect Without proper program reporting policies and procedures, the submission of late reports is noncompliance with Federal regulation and could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-003 – Reporting – Federal Accountability and Transparency Act Subaward Reporting System (FFATA) Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of one subawards tested (100%), the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 0 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 75,000 $ 75,000 $ 0 $ 0 $ 0 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-federal entity is required to report each obligating action to FSRS. The action must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment was made. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely. Questioned Costs There were no questioned costs related to reporting. Cause The College misinterpreted the absence of Department of Defense NSA CFDA # / ALN # 12.905 from the Compliance Supplement Compliance Matrix as an indication that this award was not subject to the subrecipient monitoring components of the Uniform Guidance and the Compliance Supplement. Prevalence Frequent. One out of one subawards selected for testing. Effect Without proper program reporting policies and procedures, the submission of late reports is noncompliance with Federal regulation and could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-003 – Reporting – Federal Accountability and Transparency Act Subaward Reporting System (FFATA) Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of one subawards tested (100%), the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 0 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 75,000 $ 75,000 $ 0 $ 0 $ 0 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-federal entity is required to report each obligating action to FSRS. The action must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment was made. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely. Questioned Costs There were no questioned costs related to reporting. Cause The College misinterpreted the absence of Department of Defense NSA CFDA # / ALN # 12.905 from the Compliance Supplement Compliance Matrix as an indication that this award was not subject to the subrecipient monitoring components of the Uniform Guidance and the Compliance Supplement. Prevalence Frequent. One out of one subawards selected for testing. Effect Without proper program reporting policies and procedures, the submission of late reports is noncompliance with Federal regulation and could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-004 – Internal Controls for Subrecipient Monitoring Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline noting a risk assessment took place and ongoing monitoring was occurring, there was no formal documentation of the risk assessment. Criteria Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that reviews are formally documented over subrecipient monitoring. Questioned Costs There were no questioned costs related to reporting. Cause The National Security Agency pre-selected the subrecipient college for this grant. As a result, the College did not fully utilize its subrecipient monitoring tool to document its rigorous subrecipient risk assessment and monitoring process. Prevalence Frequent. One out of one subawards selected for testing. Effect Lack of properly documented evidence of subrecipient monitoring policies and procedures could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that subrecipient monitoring policies and procedures are properly documented for each subaward. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-004 – Internal Controls for Subrecipient Monitoring Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline noting a risk assessment took place and ongoing monitoring was occurring, there was no formal documentation of the risk assessment. Criteria Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that reviews are formally documented over subrecipient monitoring. Questioned Costs There were no questioned costs related to reporting. Cause The National Security Agency pre-selected the subrecipient college for this grant. As a result, the College did not fully utilize its subrecipient monitoring tool to document its rigorous subrecipient risk assessment and monitoring process. Prevalence Frequent. One out of one subawards selected for testing. Effect Lack of properly documented evidence of subrecipient monitoring policies and procedures could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that subrecipient monitoring policies and procedures are properly documented for each subaward. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-004 – Internal Controls for Subrecipient Monitoring Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline noting a risk assessment took place and ongoing monitoring was occurring, there was no formal documentation of the risk assessment. Criteria Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that reviews are formally documented over subrecipient monitoring. Questioned Costs There were no questioned costs related to reporting. Cause The National Security Agency pre-selected the subrecipient college for this grant. As a result, the College did not fully utilize its subrecipient monitoring tool to document its rigorous subrecipient risk assessment and monitoring process. Prevalence Frequent. One out of one subawards selected for testing. Effect Lack of properly documented evidence of subrecipient monitoring policies and procedures could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that subrecipient monitoring policies and procedures are properly documented for each subaward. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-004 – Internal Controls for Subrecipient Monitoring Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline noting a risk assessment took place and ongoing monitoring was occurring, there was no formal documentation of the risk assessment. Criteria Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that reviews are formally documented over subrecipient monitoring. Questioned Costs There were no questioned costs related to reporting. Cause The National Security Agency pre-selected the subrecipient college for this grant. As a result, the College did not fully utilize its subrecipient monitoring tool to document its rigorous subrecipient risk assessment and monitoring process. Prevalence Frequent. One out of one subawards selected for testing. Effect Lack of properly documented evidence of subrecipient monitoring policies and procedures could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that subrecipient monitoring policies and procedures are properly documented for each subaward. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-004 – Internal Controls for Subrecipient Monitoring Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline noting a risk assessment took place and ongoing monitoring was occurring, there was no formal documentation of the risk assessment. Criteria Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that reviews are formally documented over subrecipient monitoring. Questioned Costs There were no questioned costs related to reporting. Cause The National Security Agency pre-selected the subrecipient college for this grant. As a result, the College did not fully utilize its subrecipient monitoring tool to document its rigorous subrecipient risk assessment and monitoring process. Prevalence Frequent. One out of one subawards selected for testing. Effect Lack of properly documented evidence of subrecipient monitoring policies and procedures could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that subrecipient monitoring policies and procedures are properly documented for each subaward. Views of responsible officials We agree with this finding. See corrective action plan.
Finding Number: 2023‐001 Repeat Finding: No Program Name/Assistance Listing Title: CBDG‐Entitlement Grants Cluster Assistance Listing Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Federal Award Numbers: B‐20‐MC‐04‐0503, B‐21‐MC‐04‐0503, B‐22‐MC‐04‐0503, and B‐20‐MW‐04‐0503 Pass‐Through Agency: N/A Questioned Costs: $0 Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Reporting Criteria Under 2 CFR §200.303, the City is required to establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the City is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CDBG program regulations require the City to file financial reports throughout the year. First, the City is required to file accurate PR26‐CDBG Financial Summary and the PR26‐CDBG‐CV Financial Summary Reports within 90 days after fiscal year end. Second, the City is also required to file PR29 – CDBG Cash on Hand and PR29 – CDBG‐CV Cash On Hand Reports by the end of the month subsequent to each quarter end. 2 CFR Part 170 requires the City to submit subaward information through the FFATA Subaward Reporting System (FSRS) in compliance with the Federal Funding Accountability and Transparency Act by the end of the month subsequent to the award. Condition Reporting obligations were not completed timely or accurately. Cause The Community Assistance Office experienced turnover and vacancies in key positions responsible for reporting during fiscal year 2020‐21. Training was needed for program employees to fully understand reporting responsibilities for the City. In some cases information was not retained and required recreation. Effect The City was not fully in compliance with reporting requirements. Context We noted the following items when reviewing reports submitted for the CDBG program. The PR26 reports for the 2020 and 2021 program years contained inaccuracies in the beginning unexpended CDBG funds, program income, or expenditure activity for each year. The City corrected these inaccuracies to properly present information on the PR26 report for program year 2023. The City did not submit PR29 reports for both the CDBG and CDBG‐CV programs quarterly. The last PR29 report submitted was for the quarter ended December 31, 2021 before the City completed all delinquent reporting in October 2023. The City was submitting the FFATA reporting annually rather than by the end of the month subsequent to an award. Recommendation The City should dedicate time and resources to allow individuals to resolve discrepancies in reporting within the Community Assistance Office. Views Of Responsible Officials See Corrective Action Plan.
Finding Number: 2023‐001 Repeat Finding: No Program Name/Assistance Listing Title: CBDG‐Entitlement Grants Cluster Assistance Listing Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Federal Award Numbers: B‐20‐MC‐04‐0503, B‐21‐MC‐04‐0503, B‐22‐MC‐04‐0503, and B‐20‐MW‐04‐0503 Pass‐Through Agency: N/A Questioned Costs: $0 Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Reporting Criteria Under 2 CFR §200.303, the City is required to establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the City is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CDBG program regulations require the City to file financial reports throughout the year. First, the City is required to file accurate PR26‐CDBG Financial Summary and the PR26‐CDBG‐CV Financial Summary Reports within 90 days after fiscal year end. Second, the City is also required to file PR29 – CDBG Cash on Hand and PR29 – CDBG‐CV Cash On Hand Reports by the end of the month subsequent to each quarter end. 2 CFR Part 170 requires the City to submit subaward information through the FFATA Subaward Reporting System (FSRS) in compliance with the Federal Funding Accountability and Transparency Act by the end of the month subsequent to the award. Condition Reporting obligations were not completed timely or accurately. Cause The Community Assistance Office experienced turnover and vacancies in key positions responsible for reporting during fiscal year 2020‐21. Training was needed for program employees to fully understand reporting responsibilities for the City. In some cases information was not retained and required recreation. Effect The City was not fully in compliance with reporting requirements. Context We noted the following items when reviewing reports submitted for the CDBG program. The PR26 reports for the 2020 and 2021 program years contained inaccuracies in the beginning unexpended CDBG funds, program income, or expenditure activity for each year. The City corrected these inaccuracies to properly present information on the PR26 report for program year 2023. The City did not submit PR29 reports for both the CDBG and CDBG‐CV programs quarterly. The last PR29 report submitted was for the quarter ended December 31, 2021 before the City completed all delinquent reporting in October 2023. The City was submitting the FFATA reporting annually rather than by the end of the month subsequent to an award. Recommendation The City should dedicate time and resources to allow individuals to resolve discrepancies in reporting within the Community Assistance Office. Views Of Responsible Officials See Corrective Action Plan.
Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Federal Agency: U.S. Department of Energy Federal Program Name: Transportation of Transuranic Wastes to the Waste Isolation Pilot Plant Assistance Listing Number: 81.106 Federal Award Identification Number and Year: DE-EM0005215 - 2020 Award Period: 7/01/2020 – 6/30/2025 Budget Period: 7/01/2022 – 6/30/2023 Criteria or specific requirement: As a recipient of federal awards, the Board is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Under the Federal Funding Accountability and Transparency Act of 2006 (FFATA) (Public Law 109-282), as codified in Title 2 CFR Part 170, Reporting Subaward and Executive Compensation Information, recipients of grants or cooperative agreements, including the Board, who make first-tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Subaward data, such as the subaward date, subawardee Data Universal Numbering System number, amount of subaward, subaward obligation/action date, date of report submission, and subaward number, are submitted through the FSRS and accessible to the general public through the USASpending.gov website. Condition: Our examination of reporting requirements associated with the program during the year ended June 30, 2023 revealed that the Board failed to submit subaward data to the FSRS for all 11 first-tier subawards. Therefore, all first-tier subawards of $30,000 or more, and the associated subaward data, was not reflected on the USASpending.gov website as required. Questioned costs: None. Cause: Oversight by management. Effect: The auditor noted instances of noncompliance due to the lack of FFATA reporting. Transparency objectives associated with FFATA reporting requirements were not achieved due to this noncompliance. Recommendation: We recommend the Board establish policies and procedures associated with FFATA reporting requirements and maintain appropriate documentation of subaward agreements and the determination of the applicable FFATA reporting requirements. Views of responsible officials: Management agrees with this isolated audit finding. The Waste Isolation Pilot Plant Cooperative Agreement consists of five one-year budget periods for 11 state agencies, and Budget Period 3 recently ended on June 30, 2023. This project is incrementally funded over the course of each one-year budget period. Therefore, each state subrecipient is tracked per each invoice submitted against the funds obligated throughout the course of the budget period/project. Funding is obligated to state subrecipients based on their spending patterns and incremental funding from DOE, which happens multiple times within each budget period and per state subrecipient. It is important to note that in previous budget periods, funds obligated to the state subrecipients were reported to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and the FFATA reporting requirements were fulfilled. As of August 23, 2023, Budget Period 3 subawardee obligated funds were reported to the FSRS and the FFATA reporting requirement have been fulfilled. During this isolated incident that has resulted in an audit finding, management has revised policies and procedures to implement additional tracking and checklists for the FSRS reporting requirement for subawards that include modifications for incremental funding. This will ensure that this requirement is reported to FSRS each time the Board receives incremental funding from DOE, which is obligated to one of the 11 state agencies as stipulated in the cooperative agreement. The Director of Business Operations and Assistant Director of Business Operations are the responsible staff.
Program - AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment Grant Number & Year - SLFRP3090, March 3, 2021, through December 31, 2024 Federal Grantor Agency - U.S. Department of the Treasury Criteria - Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2023) states the following, in relevant part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2023), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. 2 CFR § 200.214 (January 1, 2023) states the following: Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR § 180.300 (January 1, 2023) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by: "(a) Checking SAM Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . . [entity]." A good internal control plan requires the County to have proper procedures in place to verify that contractors paid with Federal funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities. Condition - Knox County could not provide documentation to support that the County implemented effective internal controls to ensure that suspension and debarment requirements were followed and adequately documented. We noted the County used Coronavirus State and Local Fiscal Recovery Funds to pay three vendors over $25,000, totaling $633,021, during the fiscal year ended June 30, 2023. The County failed to ensure that these vendors were not excluded or disqualified prior to entering into these covered transactions. We reviewed SAM.gov, and noted that none of these vendors were suspended, debarred, or otherwise excluded from participation in Federal programs or activities as of the date testing was performed. Repeat Finding - No Questioned Costs - None Statistical Sample - No Context - The following table provides details of the covered transactions noted: Cause - Lack of procedures and knowledge regarding suspension and debarment requirements Effect - Without adequate procedures to ensure contractors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions. Recommendation - We recommend the County implement procedures to ensure, prior to entering into a covered transaction, that a contractor is not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. View of Officials - The County has discussed checking the SAM (System for Award Management formerly Excluded Parties Listing System (EPLS), which is maintained by the General Services Administration to ensure vendors are not suspended or debarred before entering a transaction.
Finding 2023-001 Lack of Internal Control over Reporting Federal Agency: U.S. Department of Education Federal Program: Alaska Native Education Program ALN: 84.356 Award Numbers: S356A220034 and S356A190012. Award Years: 2022 and 2019, respectively. Type of Finding: Significant deficiency in internal control over compliance and noncompliance. Criteria: Title 2 CFR 200.303 requires the District to establish and maintain effective internal control over the federal award that provides reasonable assurance that the District 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 Alaska Native Education Programs did not occur for 2 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 2 2 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $180,224 $180,224 $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 District 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.
Finding 2023-001 Lack of Internal Control over Reporting Federal Agency: U.S. Department of Education Federal Program: Alaska Native Education Program ALN: 84.356 Award Numbers: S356A220034 and S356A190012. Award Years: 2022 and 2019, respectively. Type of Finding: Significant deficiency in internal control over compliance and noncompliance. Criteria: Title 2 CFR 200.303 requires the District to establish and maintain effective internal control over the federal award that provides reasonable assurance that the District 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 Alaska Native Education Programs did not occur for 2 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 2 2 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $180,224 $180,224 $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 District 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.
Program - AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Suspension & Debarment Grant Number & Year - SLFRP0874, March 3, 2021, through December 31, 2024 Federal Grantor Agency - U.S. Department of the Treasury Criteria - Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2023) states the following, in relevant part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR § 200.214 (January 1, 2023) states the following: Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2023), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. 2 CFR § 180.300 (January 1, 2023) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by, “(a) Checking SAM Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . . [entity].” A good internal control plan requires the County to have proper procedures in place toverify that contractors paid with Federal funds are not suspended, debarred, or otherwiseexcluded from or ineligible for participation in Federal programs or activities. Condition - Dakota County could not provide documentation to support that the County implemented effective internal controls to ensure that suspension and debarment requirements were followed and adequately documented. We noted the County used Coronavirus State and Local Fiscal Recovery Funds to pay 14 vendors over $25,000 each, totaling $1,033,366, during the fiscal year ended June 30, 2023. The County failed to ensure that these vendors were not excluded or disqualified prior to entering into these covered transactions. We reviewed SAM.gov, and noted that none of these vendors were suspended, debarred, or otherwise excluded from participation in Federal programs or activities as of the date testing was performed. Repeat Finding - No Questioned Costs - None Statistical Sample - No Cause - Lack of procedures and knowledge regarding suspension and debarment requirements. Effect - Without adequate procedures to ensure contractors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions. Recommendation - We recommend the County implement procedures to ensure, prior to entering into a covered transaction, that a contractor is not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. View of Officials - The County will implement procedures to ensure when a contractor is paid with federal funds, https://www.sam.gov will be utilized to verify the entity has not been suspended or debarred and such procedure will be adequately documented.
Information on the Major Federal Program - Federal Agency: National Science Foundation Assistance Listing Number: 47.076 Assistance Listing Name: Research and Development Cluster Award Number: 2120006 Award Period: 7/1/2022 – 6/30/2023 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “FFATA” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to identify awards subject to FFATA, collect and report information on each first tier subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. Condition - During our testing of FFATA reporting requirements, we noted for 2 subrecipients tested, there was no action taken to perform the mandatory FFATA reporting requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 2 2 2 Not applicable – not tested Not applicable – not tested Dollar Amount of Tested 2023 Subawards Transactions Subawards Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $143,838 $807,704 $807,704 Not applicable – not tested Not applicable – not tested Cause – The Company does not have adequate policies and procedures in place to ensure compliance with the requirements regarding FFATA reporting. Effect or Potential Effect - Failure to comply with the reporting requirements of the Uniform Guidance could result in noncompliance with laws and regulations. Questioned costs – None. Context - This is a condition identified based upon our review of the Company’s compliance with specified FFATA reporting requirements. The sample was selected based on a non-statistical basis. The prevalence of this finding is detailed in the condition section above. Repeat Finding – This is not a repeat finding. Recommendation - BDO recommends that the Company establish policies and procedures to ensure that the required information is collected and reported in the FFATA Subaward Reporting System. Views of Responsible Officials - Management agrees with the auditor’s comments, and the following action has been implemented to ensure that the required information is collected and reported timely in the FFATA Subaward Reporting System (FSRS). Beginning in the fiscal year 2024, the Company implemented a formal policy and procedure to file a FFATA subaward report by the end of the month following the month in which they award any sub-grant or amendment equal to or greater than $30,000 in federal funds. The Company has completed and filed the required FFATA Subaward reporting for those subgrants equal to or greater than $30,000 in federal funds and is current with the required reporting as of November 2023 and will monitor future subgrants of federal funds in order to comply with the reporting.
Program - AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment Grant Number & Year - SLFRP2377, March 3, 2021, through December 31, 2024 Federal Grantor Agency - U.S. Department of the Treasury Criteria - Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2023) states the following, in relevant part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2023), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. 2 CFR § 200.214 (January 1, 2023) states the following: Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR § 180.300 (January 1, 2023) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by: “(a) Checking SAM Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . . [entity].” A good internal control plan requires the County to have proper procedures in place to verify that contractors paid with Federal funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities. Condition - Holt County could not provide documentation to support that the County implemented effective internal controls to ensure that suspension and debarment requirements were followed and adequately documented. We noted the County used Coronavirus State and Local Fiscal Recovery Funds to pay six vendors over $25,000, totaling $1,146,781, during the fiscal year ended June 30, 2023. The County failed to ensure that these vendors were not excluded or disqualified prior to entering into these covered transactions. We reviewed SAM.gov, and noted that none of these vendors were suspended, debarred, or otherwise excluded from participation in Federal programs or activities as of the date testing was performed. Repeat Finding - No Questioned Costs - None Statistical Sample - No Context - The following table provides details of the covered transactions noted: Cause - Lack of procedures and knowledge regarding suspension and debarment requirements Effect - Without adequate procedures to ensure contractors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions. Recommendation - We recommend the County implement procedures to ensure, prior to entering into a covered transaction, that a contractor is not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. View of Officials - Holt County’s first choice will be to obtain a certificate or an agreement with each entity stating they are in good standing.
Program - AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Grant Number & Year - SLFRP2377, March 3, 2021, through December 31, 2024 Federal Grantor Agency - U.S. Department of the Treasury Criteria - Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2023) states the following, in relevant part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2023), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. The U.S. Department of the Treasury issued “Compliance and Reporting Guidance” and frequently asked questions, which specify the reporting requirements related to Coronavirus State and Local Fiscal Recovery Funds. A good internal control plan includes establishing effective internal controls through written policies and procedures to ensure Federal reporting requirements are completed accurately. Such plan should include, among other things, appropriate training on Federal reporting requirements and require a documented, detailed review of each report to be completed by a knowledgeable individual, who did not prepare the report, prior to submission. Condition - Holt County did not implement effective internal controls to ensure that the reporting requirements of the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) were completed accurately. The Project and Expenditure report submitted on April 28, 2023, did not contain accurate information for multiple expenditure and obligations categories. Repeat Finding - No Questioned Costs - None Statistical Sample - No Context - The following table summarizes the variances noted: Cause - Lack of procedures and knowledge relating to Federal reporting requirements. Effect - Inaccurate information was reported to the U.S. Department of the Treasury on the 2023 Project and Expenditure report. Additionally, there is an increased risk the County is not in compliance with the reporting requirements set by the U.S Department of the Treasury. Recommendation - We recommend the County implement procedures to ensure Federal reporting requirements are completed accurately. Such procedures could include, among other things, appropriate training on Federal reporting requirements and a documented review by a knowledgeable individual who was not involved in the preparation of the report. View of Officials - Holt County will create a spreadsheet that will track expenditures and obligations.
Program - AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment Grant Number & Year - SLFRP3105, March 3, 2021, through December 31, 2024 Federal Grantor Agency - U.S. Department of the Treasury Criteria - Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2023) states the following, in relevant part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR 1000.10 (January 1, 2023), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. 2 CFR § 200.214 (January 1, 2023) states the following: Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR § 180.300 (January 1, 2023) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by: “(a) Checking SAM Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . . [entity].” A good internal control plan requires the County to have proper procedures in place to verify that contractors paid with Federal funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities. Condition - Antelope County could not provide documentation to support the County implemented effective internal controls to ensure that suspension and debarment requirements were followed and adequately documented. We noted the County used Coronavirus State and Local Fiscal Recovery Funds to pay one vendor over $25,000, totaling $1,204,000, during the fiscal year ended June 30, 2023. The County failed to ensure that this vendor, A&R Construction, was not excluded or disqualified prior to entering into this covered transaction. We reviewed SAM.gov, and noted this vendor was not suspended, debarred, or otherwise excluded from participation in Federal programs or activities as of the date testing was performed. Repeat Finding - No Questioned Costs - None Statistical Sample - No Cause - Lack of procedures and knowledge regarding suspension and debarment requirements Effect - Without adequate procedures to ensure contractors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activies, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions. Recommendation - We recommend the County implement procedures to ensure, prior to entering into a covered transaction, that a contractor is not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. View of Officials - It will be the practice of Antelope County to check vendor status with the SAMS/DUNS before any payments are made utilizing Federal funds. To further ensure the funds are safely being utilized and spent, regular checks on the vendor status will be completed.
Program - AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Grant Number & Year - SLFRP3105, March 3, 2021, through December 31, 2024 Federal Grantor Agency - U.S. Department of the Treasury Criteria - Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2023) states the following, in relevant part: The non-Federal entity must: a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2023), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. The U.S. Department of the Treasury issued “Compliance and Reporting Guidance” and frequently asked questions, which specify the reporting requirements related toCoronavirus State and Local Fiscal Recovery Funds. A good internal control plan includes establishing effective internal controls through written policies and procedures to ensure Federal reporting requirements are completed accurately. Such plan should include, among other things, appropriate training on Federal reporting requirements and require a documented, detailed review of each report to be completed by a knowledgeable individual, who did not prepare the report, prior to submission. Condition - Antelope County did not implement effective internal controls to ensure that the reporting requirements of the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) were completed accurately. The Project and Expenditure report submitted on May 1, 2023, did not contain accurate information for multiple expenditure and obligations categories. Repeat Finding - No Questioned Costs - None Statistical Sample - No Cause - Lack of procedures and knowledge relating to Federal reporting requirements. Effect - Inaccurate information was reported to the U.S. Department of the Treasury on the 2023 Project and Expenditure report. Additionally, the there is an increased risk the County is not in compliance with the reporting requirements set by the U.S Department of the Treasury. Recommendation - We recommend the County implement procedures to ensure Federal reporting requirements are completed accurately. Such procedures could include, among other things, appropriate training on Federal reporting requirements and a documented review by a knowledgeable individual who was not involved in the preparation of the report. View of Officials - Antelope County will complete the annual expenditure report as required by ARPA Funding.
Internal Control Systems Over Special Tests and Provisions (Accountability for USDA Foods) – U.S. Department of Agriculture Food Distribution Cluster, Passed Through the State of Nevada Department of Agriculture Criteria: In accordance with 2 CFR 200.303(a), the auditee must maintain a system of internal controls to provide reasonable assurance that accurate and complete records are maintained with respect to the receipt, distribution, and inventory of USDA foods. Condition: Three Square’s internal controls, as designed, require an individual to verify that the weight of each product recorded in the inventory system is accurate. During inventory observation and testing audit procedures, twelve items were sampled. Of the twelve items, a discrepancy was discovered in the weight of one product when compared to the weight of the product recorded in the inventory system. Context: Of the twelve products selected for testing, the weight of one product was improperly recorded within Three Square’s inventory system. Cause: Internal controls over accountability for USDA foods were not operating effectively. Effect: Improper implementation of internal controls could result in improper tracking and reporting of costs of USDA foods. Recommendation: We recommend that management ensure that the system of internal controls over accountability for USDA foods is followed as designed. Views of Responsible Officials and Planned Corrective Actions: The weight of inventory is recorded within Three Square’s inventory management system as part of the receiving process. To ensure that all weight is properly recorded, Three Square will implement a verification process. Inventory control specialists, who are not part of the receiving process, will verify 10% of all items received weekly. This verification process will include independent weighing of items, and a review of the item description, quantity and dimensions recorded in the inventory management system. Any discrepancies will be reported to team leads to be rectified. Three Square is committed to ensuring that the system of internal controls is sufficient to ensure all records are accurate and complete. Anticipated completion is November 6, 2023.
Internal Control Systems Over Special Tests and Provisions (Accountability for USDA Foods) – U.S. Department of Agriculture Food Distribution Cluster, Passed Through the State of Nevada Department of Agriculture Criteria: In accordance with 2 CFR 200.303(a), the auditee must maintain a system of internal controls to provide reasonable assurance that accurate and complete records are maintained with respect to the receipt, distribution, and inventory of USDA foods. Condition: Three Square’s internal controls, as designed, require an individual to verify that the weight of each product recorded in the inventory system is accurate. During inventory observation and testing audit procedures, twelve items were sampled. Of the twelve items, a discrepancy was discovered in the weight of one product when compared to the weight of the product recorded in the inventory system. Context: Of the twelve products selected for testing, the weight of one product was improperly recorded within Three Square’s inventory system. Cause: Internal controls over accountability for USDA foods were not operating effectively. Effect: Improper implementation of internal controls could result in improper tracking and reporting of costs of USDA foods. Recommendation: We recommend that management ensure that the system of internal controls over accountability for USDA foods is followed as designed. Views of Responsible Officials and Planned Corrective Actions: The weight of inventory is recorded within Three Square’s inventory management system as part of the receiving process. To ensure that all weight is properly recorded, Three Square will implement a verification process. Inventory control specialists, who are not part of the receiving process, will verify 10% of all items received weekly. This verification process will include independent weighing of items, and a review of the item description, quantity and dimensions recorded in the inventory management system. Any discrepancies will be reported to team leads to be rectified. Three Square is committed to ensuring that the system of internal controls is sufficient to ensure all records are accurate and complete. Anticipated completion is November 6, 2023.
Internal Control Systems Over Special Tests and Provisions (Accountability for USDA Foods) – U.S. Department of Agriculture Food Distribution Cluster, Passed Through the State of Nevada Department of Agriculture Criteria: In accordance with 2 CFR 200.303(a), the auditee must maintain a system of internal controls to provide reasonable assurance that accurate and complete records are maintained with respect to the receipt, distribution, and inventory of USDA foods. Condition: Three Square’s internal controls, as designed, require an individual to verify that the weight of each product recorded in the inventory system is accurate. During inventory observation and testing audit procedures, twelve items were sampled. Of the twelve items, a discrepancy was discovered in the weight of one product when compared to the weight of the product recorded in the inventory system. Context: Of the twelve products selected for testing, the weight of one product was improperly recorded within Three Square’s inventory system. Cause: Internal controls over accountability for USDA foods were not operating effectively. Effect: Improper implementation of internal controls could result in improper tracking and reporting of costs of USDA foods. Recommendation: We recommend that management ensure that the system of internal controls over accountability for USDA foods is followed as designed. Views of Responsible Officials and Planned Corrective Actions: The weight of inventory is recorded within Three Square’s inventory management system as part of the receiving process. To ensure that all weight is properly recorded, Three Square will implement a verification process. Inventory control specialists, who are not part of the receiving process, will verify 10% of all items received weekly. This verification process will include independent weighing of items, and a review of the item description, quantity and dimensions recorded in the inventory management system. Any discrepancies will be reported to team leads to be rectified. Three Square is committed to ensuring that the system of internal controls is sufficient to ensure all records are accurate and complete. Anticipated completion is November 6, 2023.
Program - AL #21.027 – COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Reporting Grant Number & Year - SLFRP2949, March 3, 2021, through December 31, 2024 Federal Grantor Agency - U.S. Department of the Treasury Criteria - Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2023) states the following, in relevant part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘‘Standards for Internal Control in the Federal Government’’ issued by the Comptroller General of the United States or the ‘‘Internal Control Integrated Framework’’, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2023), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. The U.S. Department of the Treasury issued “Compliance and Reporting Guidance” and frequently asked questions, which specify the reporting requirements related to Coronavirus State and Local Fiscal Recovery Funds. Such guidance required the completion of a Project and Expenditure Report by April 30, 2023. A good internal control plan includes establishing effective internal controls through written policies and procedures to ensure Federal reporting requirements are completed accurately. Such plan should include, among other things, appropriate training on Federal reporting requirements and require a documented, detailed review of each report to be completed by a knowledgeable individual, who did not prepare the report, prior to submission. Condition - Lincoln County did not implement effective internal controls to ensure that the reporting requirements of the Coronavirus State and Local Fiscal Recovery Funds were completed accurately. Consequently, the Project and Expenditure Report submitted on April 7, 2023, did not contain accurate information. Repeat Finding - Yes Questioned Costs - None Statistical Sample - No Context - Lincoln County reported Current Period Expenditures of $5,355,379; however, this amount did not include an expenditure of $253,681 made on November 28, 2022. Additionally, all expenditures were reported under one project using Project Expenditure Category of Revenue Replacement and Project Expenditure Subcategory as Provision of Government Services. Based on the expenditures made by Lincoln County using Coronavirus State and Local Fiscal Recovery Funds, it appears more appropriate for the County to have reported two projects. The first project provided $189,305 to local non-profits to support their food pantry operations. As such, it appears a Project Category of Negative Economic Impacts, and a project subcategory of Aid to Nonprofit Organizations would be more appropriate. The second project included expenses totaling $5,419,755 and was correctly reported using a Project Category of Revenue Replacement and project subcategory of Provision of Government Services. The Project Description on the Project and Expenditure Report described the County's efforts to provide food assistance. As only $189,305, or 3.5% of the reported expenditures, was paid to non-profit entities, it appears that a Project Description outlining how that majority of the funds were spent would be more appropriate. Cause - Lack of procedures and knowledge relating to Federal reporting requirements. Effect - Inaccurate information was reported to the U.S. Department of the Treasury on the April 2023 Project and Expenditure report. Additionally, the County is not in compliance with the reporting requirements set by the U.S. Department of the Treasury. Recommendation - We recommend Lincoln County establish written policies and procedures to ensure Federal reporting requirements are completed accurately. Such procedures should include, among other things, appropriate training on Federal reporting requirements and a documented review by a knowledgeable individual who was not involved in the preparation of the report. View of Officials - West Central NE Development District will need to collect reports from various offices (County Clerk & County Treasurer) to verify all expenditures and disbursements match and perform their own calculations.
Program - AL #21.027 – COVID-19 Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Grant Number & Year - SLFRP2949, March 3, 2021, through December 31, 2024 Federal Grantor Agency - U.S. Department of the Treasury Criteria - Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2023) states the following, in relevant part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR § 200.214 (January 1, 2023) states the following: Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2023), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. 2 CFR § 180.300 (January 1, 2023) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by “(a) Checking SAM Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . . [entity].” A good internal control plan requires the County to have proper procedures in place to verify that all contractors paid with Federal funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities. Condition - Lincoln County had controls in place to ensure that suspension and debarment requirements were followed and adequately documented; however, the County did not follow these controls for every vendor. We noted the County used Coronavirus State and Local Fiscal Recovery Funds to pay seven vendors over $25,000 each, totaling $5,540,320, during the fiscal year ended June 30, 2023. The County failed to ensure that these vendors, with whom the County regularly does business, were not excluded or disqualified prior to entering into these covered transactions. We reviewed SAM.gov, and noted that none of these vendors were suspended, debarred, or otherwise excluded from participation in Federal programs or activities as of the date testing was performed. Repeat Finding - No Questioned Costs - None Statistical Sample - No Context - The following table provides details of the covered transactions noted: Cause - Lack of procedures and knowledge regarding suspension and debarment requirements. Effect - Without adequate procedures to ensure all contractors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions. Recommendation - We recommend the County implement procedures to ensure, prior to entering into a covered transaction, that all contractors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. View of Officials - Lincoln County (submitting Department and County Clerk’s Office) will verify through Sam.Gov that all claims submitted for payment using federal funds are not suspended, debarred, or excluded from receiving federal dollars prior to payment of the claim.
Repeat Finding: No Program Name/Assistance Listing Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Pass-Through Agency: N/A Federal Award Number: N/A Type of Finding: Significant Deficiency CRITERIA: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-Federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. CONDITION: Verification of suspension and debarment was not performed for all vendors with whom the Town spent at least $25,000 using federal grant monies. QUESTIONED COSTS: N/A CONTEXT: Payments exceeding $25,000 were made to 6 vendors totaling $768,885 for the fiscal year ended June 30, 2023. Total expenditures for the Coronavirus State and Local Fiscal Recovery Plan were $789,178 for the fiscal year ended June 30, 2023. CAUSE: The internal controls over the suspension and debarment were not adequately designed or implemented. EFFECT: Payments could be made to parties who are suspended or debarred and not be identified by management. RECOMMENDATION: Officials should implement policies and procedures which ensure compliance for parties subject to the suspension and debarment requirement. VIEWS OF RESPONSIBLE OFFICIALS: Management concurs with the finding and has developed a plan to correct the finding. See corrective action plan.
Finding 2023-003 Program Information: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.268 and 84.063 Grant Award Period: July 1, 2022 through June 30, 2023 Grant Identification Numbers: N/A Compliance Requirement: Enrollment Reporting Criteria: 2 CFR 682.309(b)(2) and 2 CFR 690.83(b)(2) requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant has been made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-timebasis for the period for which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Conditions Found: During testwork over enrollment reporting, we selected 39 students who graduated from the College during the fiscal year. We identified 5 students out of 39 selected whose enrollment status was not reported to the National Student Loan Data System (NSLDS). Management performed an additional analysis and identified that the enrollment status for 46 out of 179 students who graduated in fiscal year 2023 were not reported to NSLDS. Further, it was identified that the College did not have effective internal controls over enrollment reporting in accordance with 2 CFR 200.303. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None identified Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: During the year, the College submitted its listing of individuals who graduated to Clearinghouse to upload to NSLDS. However, the College did not review the listing of exceptions from Clearinghouse related to the students whose status changes were not uploaded to NSLDS, which caused the enrollment changes for students who graduated to not be reported in accordance with federal requirements. This caused students to not be reported to NDLDS until the audit. Recommendation: We recommend the College enhance its internal control to ensure that the College has effective internal controls in place to ensure that the College conforms to required enrollment reporting as set forth in 2 CFR 682.309(b)(2) and 2 CFR 690.83(b)(2). View of Responsible Officials: We concur with the finding and are in the process of implementing controls over reviewing exception reports for submissions to Clearinghouse to ensure that all individuals with enrollment status changes are appropriately reported to NSLDS.
Finding 2023-003 Program Information: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.268 and 84.063 Grant Award Period: July 1, 2022 through June 30, 2023 Grant Identification Numbers: N/A Compliance Requirement: Enrollment Reporting Criteria: 2 CFR 682.309(b)(2) and 2 CFR 690.83(b)(2) requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant has been made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-timebasis for the period for which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Conditions Found: During testwork over enrollment reporting, we selected 39 students who graduated from the College during the fiscal year. We identified 5 students out of 39 selected whose enrollment status was not reported to the National Student Loan Data System (NSLDS). Management performed an additional analysis and identified that the enrollment status for 46 out of 179 students who graduated in fiscal year 2023 were not reported to NSLDS. Further, it was identified that the College did not have effective internal controls over enrollment reporting in accordance with 2 CFR 200.303. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None identified Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: During the year, the College submitted its listing of individuals who graduated to Clearinghouse to upload to NSLDS. However, the College did not review the listing of exceptions from Clearinghouse related to the students whose status changes were not uploaded to NSLDS, which caused the enrollment changes for students who graduated to not be reported in accordance with federal requirements. This caused students to not be reported to NDLDS until the audit. Recommendation: We recommend the College enhance its internal control to ensure that the College has effective internal controls in place to ensure that the College conforms to required enrollment reporting as set forth in 2 CFR 682.309(b)(2) and 2 CFR 690.83(b)(2). View of Responsible Officials: We concur with the finding and are in the process of implementing controls over reviewing exception reports for submissions to Clearinghouse to ensure that all individuals with enrollment status changes are appropriately reported to NSLDS.
Department of Health and Human Services Federal Assistance Listing #93.498 COVID‐19 Provider Relief Fund and American Rescue Plan Applicable Federal Award Number and Year – Period 4 TIN #426037649 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 federal awards that provides reasonable assurance that the Medical Center is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Condition: The Medical Center did not exclude the prior audit’s questioned costs from the calculation of lost revenue. Cause: The Medical Center did not have an internal control process in place to ensure the lost revenue calculation reported under the federal program submitted to the Department of Health and Human Services for Period 4 properly excluded the prior audit’s questioned costs from the lost revenue reported. Effect: Without excluding the prior audit’s questioned costs from the lost revenue calculation, the HHS Period 4 Special Report submitted was not accurately completed. Questioned Costs: There were no questioned costs related to the lost revenue calculation, as no lost revenue was claimed to cover funds received. Context: Key line items were tested on the Period 4 Department of Health and Human Services Special Report. Repeat Finding from Prior Years: Yes, Finding #2021‐003 Recommendation: We recommend the Medical Center implement a control process which includes verifying that the lost revenue calculation reported properly includes and excludes all relevant information. 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 Applicable Federal Award Number and Year – Period 4 TIN #426037649 Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Reporting Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Medical Center is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Condition: The Medical Center included expenses in excess of the Executive Level II limit in the detail of eligible expenditures. Cause: The Medical Center did not have an internal control process in place to ensure all employees with salaries over the Executive Level II limit had their wages reimbursed by the program limited to the Executive Level II limit. Effect: Without internal control process in place to ensure all employees with salaries over the Executive Level II limit had their wages reimbursed by the program limited to the Executive Level II limit, the allowable expenses was not accurately calculated. Questioned Costs: None over the $25,000 limit. Context: A nonstatistical sample of 65 ($20,973) from a population exceeding 250 items ($2,556,270) were tested for activities allowed or unallowed and allowable costs/cost principles. Repeat Finding from Prior Years: Yes, Finding #2021‐003 Recommendation: We recommend the Medical Center implement a control process which ensures that all employees with salaries over the Executive Level II limit have their wages reimbursed by the program limited to the Executive Level II limit. Views of Responsible Officials: Management agrees with the finding.
2023-002 - Expenditure Controls - Significant Deficiency Compliance Requirement: Allowable Costs and Cost Principles ALN: 84.425 Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) 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: During our sample testing of 34 transactions for allowable costs and proper internal controls, we noted there was a lack of documentation of internal controls processes in place over compliance. For credit card charges and other expenditures, we found 11 of 34 transactions tested, did not have pre-authorized purchase order approval, prior to the charge. Questioned Costs: None. Cause: Insufficient staffing and training to ensure proper protocols are followed seems to be the main cause of this finding. Effect: Without proper internal controls, there is greater risk of unallowable expenditures being charged to the grant. Allowable costs could be charged to federal awards with reasonable assurance of compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Recommendation: We recommend that the District continue to work on implementation of expenditure controls at all school levels before the expenditure is submitted to the accounting department for payment execution.
Finding 2023-001- Allowable Activities (Significant Deficiency) Information on the federal program: U.S. Department of Treasury, Assistance Listing No. 21.027 Coronavirus Fiscal Recovery Funds Criteria: 2 CFR 200.302 and 2 CFR 200.303 require entities to establish and maintain internal controls and financial management procedures to provide reasonable assurance the award is managed in compliance with statutes, regulations, and terms and conditions of the award and to ensure federal award expenditures adequately supported by source documentation. Condition: We tested controls over disbursements to 9 hospitals during the year. For each hospital to receive funding they were to submit a staffing spreadsheet reporting their increased staffing costs due to COVID. Of the 9 tested, 4 hospitals supporting documentation was not readily available. Additional information, therefore, had to be obtained from the hospital to support the information reported by the hospital in the staffing spreadsheet. In addition, one of the 4 tested could not provide documentation that agreed to the amounts reported on the staffing spreadsheet. Cause: Salary information obtained in support of the staffing spreadsheet included Form 941, Employees Quarterly Federal Tax Return (941). However, some 941s are combined with other hospitals or filed by agency and did not agree to amounts submitted for reimbursement. Additional general ledger information had to be requested from the hospitals during the audit to reconcile to the amounts reported in the staffing spreadsheet. Effect: Internal Controls were not properly implemented to obtain source documentation to adequately support the amounts reported by the hospitals as additional staffing costs. Recommendation: We recommend the Organization strengthen its policies and procedures surrounding disbursements to hospitals to ensure the amounts reported were determined accurate and source documentation is retained to ensure compliance requirements. Views of Responsible Officials and Planned Corrective Action: See Management’s View and Corrective Action Plan included at the end of the report.
2023-002 Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010 - Title I Passed-through Colorado Department of Education Award Number - 4010, 5010, 7010; Award Year 2023 Criteria: According to 2 CFR Part 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were followed. Questioned Costs: None. Context: The District was unable to provide any supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2023. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: The District experienced departmental turnover during fiscal year 2023. As there were no checklists or procedures manuals in place, employees within the responsible department were unaware of the internal controls in place over the Assessment System Security process they were required to follow. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Strategy and Data Acquisition Education Insights Department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District and Department should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding 2023-001 Assistance Listing # 84.425U, TCLAS ESSER III, TCLAS High-Quality Afterschool, ARP ESSER III, Department of Education passed through Texas Education Agency Compliance Requirement: Reporting Significant Deficiency in Controls over Compliance Criteria or Specific Requirement The Charter Holder is responsible for establishing and maintaining effective internal control over the federal award in accordance with 2 CFR section 200.303(a). Condition and Context During testing for reporting, we noted that Charter Holder did not establish and maintain effective internal controls over the preparation and submission of the required annual report. Cause Due to the complexity and deadline to submit the annual report, the Charter Holder had only the CFO prepare and submit the report. Effect or Potential Effect Without a level of internal review of the report before submittal, the Charter Holder may submit a report that contains errors. Questioned Costs None. Recommendation The Charter Holder should establish and maintain internal controls over the preparation and submission of the required annual report. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.
2023-006 – ACTIVITIES ALLOWED OR UNALLOWED Type: Significant Deficiency in Internal Control Program: ALN 84.425 Education Stabilization Fund, COVID-19 - ESSER II – Summer School and ESSER II – 98c Criteria: As detailed by 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 testing of amounts charged to the grants, it was noted that several items charged to the grant did not have proper approval signatures. Cause/Effect: This condition appears to be the result of a vacancy in the business manager position. Recommendation: We recommend that the District establish/modify internal controls to assure that internal controls are maintained/alternate internal controls are in place when a key position is vacant. View of Responsible Official: Management is in agreement with this recommendation
2023-006 – ACTIVITIES ALLOWED OR UNALLOWED Type: Significant Deficiency in Internal Control Program: ALN 84.425 Education Stabilization Fund, COVID-19 - ESSER II – Summer School and ESSER II – 98c Criteria: As detailed by 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 testing of amounts charged to the grants, it was noted that several items charged to the grant did not have proper approval signatures. Cause/Effect: This condition appears to be the result of a vacancy in the business manager position. Recommendation: We recommend that the District establish/modify internal controls to assure that internal controls are maintained/alternate internal controls are in place when a key position is vacant. View of Responsible Official: Management is in agreement with this recommendation
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Special Programs for the Aging Assistance Listing Number: 93.Aging Cluster Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition/Context: For 21 of the 21 cash disbursements tested, there was no indication of review and approval over the expense by a secondary, independent individual separate from the requestor. Criteria or specific requirement: In accordance with the Compliance Supplement, Part 6 – Internal Control, 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Cause: The Organization did not have established sufficient controls designed to ensure adequate segregation of duties in the cash distribution process. Disbursements to US Foods were established as an automatic debit and therefore did not have individual approvals. Effect: The Organization was not in compliance with the Compliance Supplement related to establishing and maintaining internal controls over federal awards. Repeat Finding: No Recommendation: We recommend that the Organization implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Views of responsible officials: Management agrees with the audit condition.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Special Programs for the Aging Assistance Listing Number: 93.Aging Cluster Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition/Context: For the calculation of the 15% non-federal matching contribution requirement, there was no indication of review or approval by a secondary, independent individual separate from the preparer. Criteria or specific requirement: In accordance with the Compliance Supplement, Part 6 – Internal Control, 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Cause: The Organization did not have established internal controls designed to ensure adequate segregation of duties for calculating the matching requirement. Effect: The Organization was not in compliance with the Compliance Supplement related to establishing and maintaining internal controls over federal awards. Repeat Finding: No Recommendation: We recommend that the Organization implement policies and procedures that ensure the calculation of the matching requirement is reviewed and approved by a second, independent individual. Views of responsible officials: Management agrees with the audit condition.