FINDING 2023-007 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to states and school districts to combat the effects of the coronavirus, help safely reopen and sustain the safe operation of schools, and to address the impact of the coronavirus pandemic on the nation's students. States were required to subgrant a portion of their ESSER allocation to Local Educational Agencies (LEA). Prior to the LEAs receiving their respective subgrants, the LEAs were required to complete an application for ARP ESSER funding, which was submitted to the Indiana Department of Education, the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. The School Corporation did not have internal controls in place over payroll disbursements charged to the ESSER grant funds. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Additionally, a sample of 40 payroll disbursements were selected for testing. For 1 payroll disbursement selected for testing, the employee's timesheet could not be provided. As such, we could not substantiate the amount paid, $1,094, out of the grant funds. This amount was considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: INDIANA STATE BOARD OF ACCOUNTS 27 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which allocated using different allocation bases; or an unallowable activity and a direct or indirect costs activity. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal control, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, payroll charges could not be substantiated. Questioned Costs Known questioned costs of $1,094 were identified as noted in the Condition and Context. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure costs are adequately documented. INDIANA STATE BOARD OF ACCOUNTS 28 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-007 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to states and school districts to combat the effects of the coronavirus, help safely reopen and sustain the safe operation of schools, and to address the impact of the coronavirus pandemic on the nation's students. States were required to subgrant a portion of their ESSER allocation to Local Educational Agencies (LEA). Prior to the LEAs receiving their respective subgrants, the LEAs were required to complete an application for ARP ESSER funding, which was submitted to the Indiana Department of Education, the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. The School Corporation did not have internal controls in place over payroll disbursements charged to the ESSER grant funds. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Additionally, a sample of 40 payroll disbursements were selected for testing. For 1 payroll disbursement selected for testing, the employee's timesheet could not be provided. As such, we could not substantiate the amount paid, $1,094, out of the grant funds. This amount was considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: INDIANA STATE BOARD OF ACCOUNTS 27 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which allocated using different allocation bases; or an unallowable activity and a direct or indirect costs activity. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal control, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, payroll charges could not be substantiated. Questioned Costs Known questioned costs of $1,094 were identified as noted in the Condition and Context. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure costs are adequately documented. INDIANA STATE BOARD OF ACCOUNTS 28 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-007 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to states and school districts to combat the effects of the coronavirus, help safely reopen and sustain the safe operation of schools, and to address the impact of the coronavirus pandemic on the nation's students. States were required to subgrant a portion of their ESSER allocation to Local Educational Agencies (LEA). Prior to the LEAs receiving their respective subgrants, the LEAs were required to complete an application for ARP ESSER funding, which was submitted to the Indiana Department of Education, the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. The School Corporation did not have internal controls in place over payroll disbursements charged to the ESSER grant funds. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Additionally, a sample of 40 payroll disbursements were selected for testing. For 1 payroll disbursement selected for testing, the employee's timesheet could not be provided. As such, we could not substantiate the amount paid, $1,094, out of the grant funds. This amount was considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: INDIANA STATE BOARD OF ACCOUNTS 27 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which allocated using different allocation bases; or an unallowable activity and a direct or indirect costs activity. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal control, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, payroll charges could not be substantiated. Questioned Costs Known questioned costs of $1,094 were identified as noted in the Condition and Context. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure costs are adequately documented. INDIANA STATE BOARD OF ACCOUNTS 28 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-007 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to states and school districts to combat the effects of the coronavirus, help safely reopen and sustain the safe operation of schools, and to address the impact of the coronavirus pandemic on the nation's students. States were required to subgrant a portion of their ESSER allocation to Local Educational Agencies (LEA). Prior to the LEAs receiving their respective subgrants, the LEAs were required to complete an application for ARP ESSER funding, which was submitted to the Indiana Department of Education, the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. The School Corporation did not have internal controls in place over payroll disbursements charged to the ESSER grant funds. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Additionally, a sample of 40 payroll disbursements were selected for testing. For 1 payroll disbursement selected for testing, the employee's timesheet could not be provided. As such, we could not substantiate the amount paid, $1,094, out of the grant funds. This amount was considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: INDIANA STATE BOARD OF ACCOUNTS 27 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which allocated using different allocation bases; or an unallowable activity and a direct or indirect costs activity. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal control, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, payroll charges could not be substantiated. Questioned Costs Known questioned costs of $1,094 were identified as noted in the Condition and Context. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure costs are adequately documented. INDIANA STATE BOARD OF ACCOUNTS 28 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-008 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed Audit Finding: Material Weakness Condition and Context The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to states and school districts to combat the effects of the coronavirus, help safely reopen and sustain the safe operation of schools, and to address the impact of the coronavirus pandemic on the nation's students. States were required to subgrant a portion of their ESSER allocation to Local Education Agencies (LEA). Prior to the LEAs receiving their respective subgrants, the LEAs were required to complete an application for ARP ESSER funding, which was submitted to the Indiana Department of Education, the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. The School Corporation did not have internal controls in place over payroll disbursements charged to the ESSER grant funds. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 29 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal control, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-008 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed Audit Finding: Material Weakness Condition and Context The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to states and school districts to combat the effects of the coronavirus, help safely reopen and sustain the safe operation of schools, and to address the impact of the coronavirus pandemic on the nation's students. States were required to subgrant a portion of their ESSER allocation to Local Education Agencies (LEA). Prior to the LEAs receiving their respective subgrants, the LEAs were required to complete an application for ARP ESSER funding, which was submitted to the Indiana Department of Education, the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. The School Corporation did not have internal controls in place over payroll disbursements charged to the ESSER grant funds. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 29 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal control, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-008 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed Audit Finding: Material Weakness Condition and Context The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to states and school districts to combat the effects of the coronavirus, help safely reopen and sustain the safe operation of schools, and to address the impact of the coronavirus pandemic on the nation's students. States were required to subgrant a portion of their ESSER allocation to Local Education Agencies (LEA). Prior to the LEAs receiving their respective subgrants, the LEAs were required to complete an application for ARP ESSER funding, which was submitted to the Indiana Department of Education, the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. The School Corporation did not have internal controls in place over payroll disbursements charged to the ESSER grant funds. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 29 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal control, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-008 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed Audit Finding: Material Weakness Condition and Context The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to states and school districts to combat the effects of the coronavirus, help safely reopen and sustain the safe operation of schools, and to address the impact of the coronavirus pandemic on the nation's students. States were required to subgrant a portion of their ESSER allocation to Local Education Agencies (LEA). Prior to the LEAs receiving their respective subgrants, the LEAs were required to complete an application for ARP ESSER funding, which was submitted to the Indiana Department of Education, the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. The School Corporation did not have internal controls in place over payroll disbursements charged to the ESSER grant funds. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 29 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal control, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-008 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed Audit Finding: Material Weakness Condition and Context The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to states and school districts to combat the effects of the coronavirus, help safely reopen and sustain the safe operation of schools, and to address the impact of the coronavirus pandemic on the nation's students. States were required to subgrant a portion of their ESSER allocation to Local Education Agencies (LEA). Prior to the LEAs receiving their respective subgrants, the LEAs were required to complete an application for ARP ESSER funding, which was submitted to the Indiana Department of Education, the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. The School Corporation did not have internal controls in place over payroll disbursements charged to the ESSER grant funds. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 29 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal control, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-009 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Number and Year (or Other Identifying Number): S425D200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit an annual data report to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were prepared by the Chief Financial Officer and reviewed by a second knowledgeable individual; however, this process did not allow for the prevention, or detection and correction, of errors prior to submission. INDIANA STATE BOARD OF ACCOUNTS 30 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Due to the lack of effective internal controls, one of the six annual data reports was not supported by the School Corporation's records. For the ESSER 1, Year 2 report, which covered the period of October 1, 2020 to June 30, 2021, the School Corporation's records did not support the data reported. The total expenditures were not correct and the key line item did not match to the records of the unit. The lack of internal controls and noncompliance were isolated to the ESSER I, Year 2 report. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER I, Year 2 report was not supported by the School Corporation's records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 31 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all expenditures are reported on the reports submitted on behalf of the COVID-19 - Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. INDIANA STATE BOARD OF ACCOUNTS 32
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-005 – Allowable Costs/Cost Principles and Cash Management Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Additionally, 2 CFR Section 200 Subpart E outlines cost provisions, including what constitutes allowable costs, and permitted allocations of costs. To be allowable, costs generally must: be necessary and reasonable for the performance of the federal award and be allocable under the principles in 2 CFR Part 200, Subpart E; conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with U.S. GAAP; not be included as a cost or used to meet cost-sharing or matching requirements; and must be adequately documented. Further, in accordance with cash management compliance requirements, expenses should be incurred prior to charging the grant. Condition and Context During our testing of certain cost reimbursement government contracts, it was determined that certain budgeted costs, including certain administrative and overhead line items, that were not actually incurred were billed by the Organization and reimbursed by the purchasing agency. The errors occurred, in part, because the Organization billed the maximum budgeted amount of administrative and overhead line items for certain contracts rather than the actual amount of costs incurred. Additionally, there was an instance where costs were not incurred prior to being billed. Cause The Organization had insufficient internal controls and policies to ensure that billings under cost reimbursement contracts did not exceed actual costs incurred (overbillings) and that billings are only submitted after expenses have been incurred. Effect or Potential Effect The Organization was not in compliance with the requirements for cost reimbursement contracting or recording in accordance with the Code of Massachusetts Regulations (CMR) and allowable cost principles set forth by the OMB (Office of Management and Budget) Uniform Guidance. This resulted in revenues that exceeded actual costs incurred of approximately $98,041. The overbillings resulted in a liability in that amount, subject to final adjustment by the Commonwealth of Massachusetts. Questioned Costs None noted. Recommendation We recommend the Organization establish internal controls and policies to ensure that costs which are not incurred are not charged to contracts and that costs are actually incurred prior to being charged to contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-007 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance Title 2 of U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D § 200.303 states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (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. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.” Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Condition and Context During our testing of payroll transactions, it was determined that certain timesheets selected did not have sufficient evidence that the timesheet was submitted by the employee and approved by the supervisor or management. Additionally, certain timesheets were not submitted timely resulting in late payment of employee compensation. Further, there were instances where dates on timesheets did not coincide with the Organization’s stated pay period. Lastly, overtime pay for hourly workers should have been remitted but was not. Cause The Organization did not maintain proper controls over payroll transactions sufficient to ensure that all timesheets were properly submitted and approved in a timely manner. Additionally, there were not controls in place to ensure that overtime pay was properly calculated and distributed. Effect or Potential Effect Failure to establish internal controls sufficient to ensure proper and timely submission and approval of employee timesheets could potentially result in errors and unallowable costs being charged to the grants and/or untimely payment of compensation to employees. Additionally, failure to establish controls around employee time reporting could result in employees not receiving overtime pay to which they were entitled. Questioned Costs None noted. Recommendations We recommend the Organization establish internal controls and policies to ensure that timesheets are tracked properly, submitted by employees and verified and approved by a supervisor, with adequate documented support of the approvals. Additionally, we recommend that the Organization establishes controls that dates on timesheet align with the Organization’s stated pay period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-008 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance with 2 CFR § 200.302, the Organizations’ financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statues, regulations, and the terms and conditions of the federal award. Additionally, as required by 2 CFR 200.302(b)(4), the non-federal entity must exercise effective control over, and accountability for, all federal funds. Per 2 CFR. 200.303(a), the non-federal entity should use the Internal Control Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) as a guideline. The COSO guideline indicates that proper segregation of duties between initiating, recording, and authorizing is a best practice as well as retaining documentation of performance and authorization controls. Condition and Context During our audit it was noted that the Organization had inadequate segregation of duties over cash disbursements. Further, written policies concerning cash management practices were not followed and there are no written policies in place regarding written approval of expenses prior to submitting requests for reimbursement. Cause Lack of segregation of incompatible tasks and written policies were not consistently followed. Effect or Potential Effect Lack of internal controls around supervising and authorizing cash management and financial management systems could result in mismanagement of federal funds. Questioned Costs None noted. Recommendations Initiating, authorizing, and recording transaction should not be performed by the same individual. Segregation of incompatible tasks should be implemented so that authorization and review of cash draws of federal or state funds is done by someone other than the individual who initiates and records the transaction. Additionally, there should be written policies in place surrounding cash management. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-008 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance with 2 CFR § 200.302, the Organizations’ financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statues, regulations, and the terms and conditions of the federal award. Additionally, as required by 2 CFR 200.302(b)(4), the non-federal entity must exercise effective control over, and accountability for, all federal funds. Per 2 CFR. 200.303(a), the non-federal entity should use the Internal Control Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) as a guideline. The COSO guideline indicates that proper segregation of duties between initiating, recording, and authorizing is a best practice as well as retaining documentation of performance and authorization controls. Condition and Context During our audit it was noted that the Organization had inadequate segregation of duties over cash disbursements. Further, written policies concerning cash management practices were not followed and there are no written policies in place regarding written approval of expenses prior to submitting requests for reimbursement. Cause Lack of segregation of incompatible tasks and written policies were not consistently followed. Effect or Potential Effect Lack of internal controls around supervising and authorizing cash management and financial management systems could result in mismanagement of federal funds. Questioned Costs None noted. Recommendations Initiating, authorizing, and recording transaction should not be performed by the same individual. Segregation of incompatible tasks should be implemented so that authorization and review of cash draws of federal or state funds is done by someone other than the individual who initiates and records the transaction. Additionally, there should be written policies in place surrounding cash management. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-008 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance with 2 CFR § 200.302, the Organizations’ financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statues, regulations, and the terms and conditions of the federal award. Additionally, as required by 2 CFR 200.302(b)(4), the non-federal entity must exercise effective control over, and accountability for, all federal funds. Per 2 CFR. 200.303(a), the non-federal entity should use the Internal Control Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) as a guideline. The COSO guideline indicates that proper segregation of duties between initiating, recording, and authorizing is a best practice as well as retaining documentation of performance and authorization controls. Condition and Context During our audit it was noted that the Organization had inadequate segregation of duties over cash disbursements. Further, written policies concerning cash management practices were not followed and there are no written policies in place regarding written approval of expenses prior to submitting requests for reimbursement. Cause Lack of segregation of incompatible tasks and written policies were not consistently followed. Effect or Potential Effect Lack of internal controls around supervising and authorizing cash management and financial management systems could result in mismanagement of federal funds. Questioned Costs None noted. Recommendations Initiating, authorizing, and recording transaction should not be performed by the same individual. Segregation of incompatible tasks should be implemented so that authorization and review of cash draws of federal or state funds is done by someone other than the individual who initiates and records the transaction. Additionally, there should be written policies in place surrounding cash management. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2023-008 – Internal Controls Over Compliance Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: No Type of Finding: Significant Deficiency in Internal Controls Over Compliance Criteria In accordance with 2 CFR § 200.302, the Organizations’ financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statues, regulations, and the terms and conditions of the federal award. Additionally, as required by 2 CFR 200.302(b)(4), the non-federal entity must exercise effective control over, and accountability for, all federal funds. Per 2 CFR. 200.303(a), the non-federal entity should use the Internal Control Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) as a guideline. The COSO guideline indicates that proper segregation of duties between initiating, recording, and authorizing is a best practice as well as retaining documentation of performance and authorization controls. Condition and Context During our audit it was noted that the Organization had inadequate segregation of duties over cash disbursements. Further, written policies concerning cash management practices were not followed and there are no written policies in place regarding written approval of expenses prior to submitting requests for reimbursement. Cause Lack of segregation of incompatible tasks and written policies were not consistently followed. Effect or Potential Effect Lack of internal controls around supervising and authorizing cash management and financial management systems could result in mismanagement of federal funds. Questioned Costs None noted. Recommendations Initiating, authorizing, and recording transaction should not be performed by the same individual. Segregation of incompatible tasks should be implemented so that authorization and review of cash draws of federal or state funds is done by someone other than the individual who initiates and records the transaction. Additionally, there should be written policies in place surrounding cash management. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.