Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, P425F202751 - 2021 Pass-through Entity - N/A Finding Type: Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The College must minimize the time elapsing between the transfer of funds from the United States Treasury to the University and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down an estimated amount for student and institutional portion prior to the funds being disbursed to students or used for allowable expenditures. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context - In November 2021, the College drew down $5,882,052 for the Student Aid portion and $5,622,717 for the Institutional Aid portion, but it did not spend the funds within the required time following cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under Uniform Guidance applied to these programs, which resulted in an excess of funds drawn down. Recommendation - We recommend the College implement a process to ensure that minimizes the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - The College reviewed its cash management policies and corrected accounting procedures are in effect December 22, 2022. Please note that the College was unaware of this requirement; in that regard, it should be recognized that College financial executives consistently and frequently met with their Ohio community college peers, including Ohio Attorney General Office staff, to understand and interpret the evolution of federal rules and guidelines for these federally designated institutional and student awards.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, P425F202751 - 2021 Pass-through Entity - N/A Finding Type: Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The College must minimize the time elapsing between the transfer of funds from the United States Treasury to the University and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down an estimated amount for student and institutional portion prior to the funds being disbursed to students or used for allowable expenditures. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context - In November 2021, the College drew down $5,882,052 for the Student Aid portion and $5,622,717 for the Institutional Aid portion, but it did not spend the funds within the required time following cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under Uniform Guidance applied to these programs, which resulted in an excess of funds drawn down. Recommendation - We recommend the College implement a process to ensure that minimizes the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - The College reviewed its cash management policies and corrected accounting procedures are in effect December 22, 2022. Please note that the College was unaware of this requirement; in that regard, it should be recognized that College financial executives consistently and frequently met with their Ohio community college peers, including Ohio Attorney General Office staff, to understand and interpret the evolution of federal rules and guidelines for these federally designated institutional and student awards.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, P425F202751 - 2021 Pass-through Entity - N/A Finding Type: Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The College must minimize the time elapsing between the transfer of funds from the United States Treasury to the University and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down an estimated amount for student and institutional portion prior to the funds being disbursed to students or used for allowable expenditures. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context - In November 2021, the College drew down $5,882,052 for the Student Aid portion and $5,622,717 for the Institutional Aid portion, but it did not spend the funds within the required time following cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under Uniform Guidance applied to these programs, which resulted in an excess of funds drawn down. Recommendation - We recommend the College implement a process to ensure that minimizes the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - The College reviewed its cash management policies and corrected accounting procedures are in effect December 22, 2022. Please note that the College was unaware of this requirement; in that regard, it should be recognized that College financial executives consistently and frequently met with their Ohio community college peers, including Ohio Attorney General Office staff, to understand and interpret the evolution of federal rules and guidelines for these federally designated institutional and student awards.
Finding 2022-002: Internal control deficiency and noncompliance over program income requirements. Identification of the federal program: Assistance Listing Number 93.918: ? Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease ? COVID-19 ? Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease ? U.S. Department of Health and Human Services ? Federal award identification numbers and award years: o 5 H76HA00151-31-00 ? January 1, 2018 to December 31, 2021 o 6 H76HA00151-31-01 ? January 1, 2018 to December 31, 2021 o 2 H76HA00151-32-00 ? January 1, 2022 to December 31, 2024 o 6 H76HA00151-32-01 ? January 1, 2022 to December 31, 2024 Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A Chapter II Part 200 Subpart D 200.303 Internal controls states: ?the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A Chapter II Part 200 Subpart D 200.305(b)(5) Federal payment states: ?To the extent available, the non-Federal entity must disburse funds available from program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, and interest earned on such funds before requesting additional cash payments.? Title 2, Subtitle A Chapter II Part 200 Subpart D 200.328 Financial reporting states: ?Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as appliable, when providing financial and performance reporting information.? The Ryan White HIV/AIDS Program and Program Income Policy Clarification Notice #15-03 states the following: ? Under the uniform administrative requirements, to the extent available, recipients and subrecipients must disburse funds available from program income, rebates, refunds, contract settlements, audit recoveries and interest earned on such funds before requesting additional cash payments. ? Recipients are required to track and account for all program income in accordance with 45 CFR 75.302(b)(3). Recipients must report program income on their Federal Financial Report (FFRs). ? Documentation of program income and accounting for its receipt and utilization will be consistent across Parts, to the extent possible. o Parts C, D, and F are discretionary awards and have multi-year periods of performance: ? Parts C, D, and F recipients must account for program income and its use within their multi-year period of performance. ? In the final year of funding, program income received at the end of the period of performance will be expended prior to new grant funds awarded in the next competitive cycle, so long as the recipient receives such subsequent award. Condition: During our review over program income, we observed management did not have internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above and was unable to provide sufficient documentation to support the program income earned by the program. Cause: Management did not have internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above and was unable to provide sufficient documentation to support the program income earned by the program. Effect or potential effect: We were unable to test program income compliance or internal controls. Questioned costs: Unknown. Context: During our review over program income, we obtained the annual financial report submitted. We observed the total federal share of program income earned incorrectly reported Ryan White HIV/AIDS Program Part A, B, C and cash receipts unrelated to the program. The reported balance was also reported based on a cash basis instead of the accrual method stated on the federal financial report. We were unable to test the amount reported on the federal financial report as the amount reported is a cumulative amount from January 1, 2018 onward and included cash receipts unrelated to the program. During our review over program income, we observed management did not track program income earned as compared to the actual expenditures incurred. We were unable to test that program income was disbursed prior to requesting additional cash payments. Identification as a repeat finding, if applicable: Yes ? Finding 2021-004. Recommendation: We recommend that management develop and implement internal controls to ensure accurate reporting in the federal financial report and tracking of program income earned as compared to the actual expenditures incurred. This will ensure program income is reported and tracked accurately. Views of responsible officials: The Ryan White Part C program project period ended December 31, 2021 and a new project period started January 1, 2022 with the first federal financial report due in April 2023. Starting with the new program year, Valleywise Health management will develop and implement internal controls to ensure that program income is accurately calculated and reported in the federal financial report.
Finding 2022-002: Internal control deficiency and noncompliance over program income requirements. Identification of the federal program: Assistance Listing Number 93.918: ? Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease ? COVID-19 ? Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease ? U.S. Department of Health and Human Services ? Federal award identification numbers and award years: o 5 H76HA00151-31-00 ? January 1, 2018 to December 31, 2021 o 6 H76HA00151-31-01 ? January 1, 2018 to December 31, 2021 o 2 H76HA00151-32-00 ? January 1, 2022 to December 31, 2024 o 6 H76HA00151-32-01 ? January 1, 2022 to December 31, 2024 Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A Chapter II Part 200 Subpart D 200.303 Internal controls states: ?the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A Chapter II Part 200 Subpart D 200.305(b)(5) Federal payment states: ?To the extent available, the non-Federal entity must disburse funds available from program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, and interest earned on such funds before requesting additional cash payments.? Title 2, Subtitle A Chapter II Part 200 Subpart D 200.328 Financial reporting states: ?Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as appliable, when providing financial and performance reporting information.? The Ryan White HIV/AIDS Program and Program Income Policy Clarification Notice #15-03 states the following: ? Under the uniform administrative requirements, to the extent available, recipients and subrecipients must disburse funds available from program income, rebates, refunds, contract settlements, audit recoveries and interest earned on such funds before requesting additional cash payments. ? Recipients are required to track and account for all program income in accordance with 45 CFR 75.302(b)(3). Recipients must report program income on their Federal Financial Report (FFRs). ? Documentation of program income and accounting for its receipt and utilization will be consistent across Parts, to the extent possible. o Parts C, D, and F are discretionary awards and have multi-year periods of performance: ? Parts C, D, and F recipients must account for program income and its use within their multi-year period of performance. ? In the final year of funding, program income received at the end of the period of performance will be expended prior to new grant funds awarded in the next competitive cycle, so long as the recipient receives such subsequent award. Condition: During our review over program income, we observed management did not have internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above and was unable to provide sufficient documentation to support the program income earned by the program. Cause: Management did not have internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above and was unable to provide sufficient documentation to support the program income earned by the program. Effect or potential effect: We were unable to test program income compliance or internal controls. Questioned costs: Unknown. Context: During our review over program income, we obtained the annual financial report submitted. We observed the total federal share of program income earned incorrectly reported Ryan White HIV/AIDS Program Part A, B, C and cash receipts unrelated to the program. The reported balance was also reported based on a cash basis instead of the accrual method stated on the federal financial report. We were unable to test the amount reported on the federal financial report as the amount reported is a cumulative amount from January 1, 2018 onward and included cash receipts unrelated to the program. During our review over program income, we observed management did not track program income earned as compared to the actual expenditures incurred. We were unable to test that program income was disbursed prior to requesting additional cash payments. Identification as a repeat finding, if applicable: Yes ? Finding 2021-004. Recommendation: We recommend that management develop and implement internal controls to ensure accurate reporting in the federal financial report and tracking of program income earned as compared to the actual expenditures incurred. This will ensure program income is reported and tracked accurately. Views of responsible officials: The Ryan White Part C program project period ended December 31, 2021 and a new project period started January 1, 2022 with the first federal financial report due in April 2023. Starting with the new program year, Valleywise Health management will develop and implement internal controls to ensure that program income is accurately calculated and reported in the federal financial report.
1. FINDING NUMBER: 2022-001 4. THIS FINDING IS: X New 2. FINDING TYPE: Compliance 3. DEFICIENCY TYPE: Reporting 3. Federal Program Name and Year: COVID-19 - ARP Elementary and Secondary School Emergency Relief - E3 4. Project No.: 22-4998-E3 5. AL No.: 84.425U 6. Passed Through: Illinois State Board of Education 7. Federal Agency: U.S. Department of Education 8. Criteria or specific requirement (including statutory, regulatory, or other citation) The Code of Federal Regulations (CFR) Title 2, part 200.305(b)(3) states that non-federal entities must disburse funds for program purposes before requesting payment from the federal awarding agency or pass-through entity. 9. Condition: The District's expenditure report filed for June 30, 2022 included expenditures paid in July and August 2022. These amounts were not reported as committed or obligated. 10. Questioned Costs: None. 11. Context: The District received federal reimbursement before expenditures were paid and did not label the expenditures as committed or obligated. 12. Effect: The June 30, 2022 expenditure report was filed overstating cash basis expenditures. The expenditure report did not include the July and August 2022 paid expenditures as committed or obligated. These expenditures were later liquidated and the final expenditure claim is correct. 13. Cause: Grant expenditures reported on the final June 30, 2022 expenditure report included expenditures that should have been reported as obligated and not included with cash basis expenditures. 14. Recommendation: Grant expenditure reports should be prepared on the cash basis and obligations reported. The liquidation of the obligations should be reported on subsequent liquidation reports. 15. Management's response: There is no disagreement with this finding and management will monitor all future federal reimbursement requests. Committed and obligated expenditures will be reported appropriately, and will be paid within 90 days after project completion.
Finding 2022-002 ? Cash Management Cluster: Research and Development Federal Agency: National Science Foundation, Department of Health and Human Services National Institutes of Health Assistance Listing Program Title and Number: Mathematical and Physical Sciences ? 47.049, Oral Diseases and Disorders Research ? 93.121 Award Identifying Number: 1935950, 5 U24DE029462 03 Award Year: July 1, 2021 to June 30, 2022 Criteria: In accordance with 2 CFR 200.305 (b), for non-federal entities other than states, payment methods associated with expenditures must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-federal entity, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the federal awarding agency sets a specific condition per 2 CFR 200.208, or when the non-federal entity requests payment by reimbursement. Per the Office of Management and Budget (?OMB?) Compliance Supplement, the non-federal entity must disburse funds for expenditures before requesting payment from the federal awarding agency or pass-through entity. Condition: In testing compliance with the cash management compliance requirement in accordance with the OMB Compliance Supplement, specifically the reimbursement method, 25 individual expenditures across three campuses were tested to compare the date the University paid the vendor to the date the University requested sponsor reimbursement. We noted two out of 25 instances in which reimbursement was requested from the sponsor before the University paid the related expenditure. Questioned Costs: None. Cause: Management?s current process across all campuses is to request reimbursement from sponsors once the expenditures are incurred, regardless of whether or not payments to vendors have been previously made. Effect: The University requested and received federal reimbursement prior to paying vendors for the selected expenditures. Recommendation: The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with federal reimbursement requirements. View of Responsible Officials: Refer to Management?s Corrective Action Plan for management?s view and corrective action plan for the finding described above.
Finding 2022-002 ? Cash Management Cluster: Research and Development Federal Agency: National Science Foundation, Department of Health and Human Services National Institutes of Health Assistance Listing Program Title and Number: Mathematical and Physical Sciences ? 47.049, Oral Diseases and Disorders Research ? 93.121 Award Identifying Number: 1935950, 5 U24DE029462 03 Award Year: July 1, 2021 to June 30, 2022 Criteria: In accordance with 2 CFR 200.305 (b), for non-federal entities other than states, payment methods associated with expenditures must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-federal entity, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the federal awarding agency sets a specific condition per 2 CFR 200.208, or when the non-federal entity requests payment by reimbursement. Per the Office of Management and Budget (?OMB?) Compliance Supplement, the non-federal entity must disburse funds for expenditures before requesting payment from the federal awarding agency or pass-through entity. Condition: In testing compliance with the cash management compliance requirement in accordance with the OMB Compliance Supplement, specifically the reimbursement method, 25 individual expenditures across three campuses were tested to compare the date the University paid the vendor to the date the University requested sponsor reimbursement. We noted two out of 25 instances in which reimbursement was requested from the sponsor before the University paid the related expenditure. Questioned Costs: None. Cause: Management?s current process across all campuses is to request reimbursement from sponsors once the expenditures are incurred, regardless of whether or not payments to vendors have been previously made. Effect: The University requested and received federal reimbursement prior to paying vendors for the selected expenditures. Recommendation: The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with federal reimbursement requirements. View of Responsible Officials: Refer to Management?s Corrective Action Plan for management?s view and corrective action plan for the finding described above.
Finding Reference Number: 2022-006 NH Governor?s Office of Emergency Relief and Recovery COVID-19 Homeowners Assistance Fund Program (Assistance Listing #21.026) Federal Award Numbers: HAFP-0190 Federal Award Year: 2021 U.S. Department of Treasury Compliance Requirement: Cash Management Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: None Statistically Valid Sample: No Criteria Pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient (2 CFR section 200.305(b)(1)). Additionally, 2 CFR section 200.303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition The State of New Hampshire Governor?s Office of Emergency Relief and Recovery (the Office) entered into a subrecipient grant agreement whereby the subrecipient is responsible for determining benefit eligibility as well as calculating the benefit amount that the participant is eligible to receive. During the year ended June 30, 2022, the Department passed through $49,250,000 to its subrecipient. Funds paid under this program were authorized to be paid in advance through a series of executive orders by the Governor?s Office to the subrecipient. While the Office properly advanced the funds, they did not monitor or assess at the time of payment what the subrecipient?s cash needs were to ensure that the Office sufficiently minimized the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes for each of the 2 transactions selected for testwork. Cause The cause of the condition found is that the Office was authorized through executive orders to issue the advance payments to the subrecipient. Given this authorization, the Office management do not consider minimizing the time elapsing between the transfer of federal funds to the subrecipient and their disbursement compliance. Per inquiry of management, we noted that the Office meets weekly with the subrecipient and as part of these meetings, cash on hand at the subrecipient level is discussed. However, there is no evidence such as meeting minutes or agendas maintained to validate that this review occurred at an appropriate precision level. Effect The effect of the condition found is that the subrecipient could have excess cash on hand as the Office did not minimize the time elapsing between the transfer of federal funds to the subrecipient and their disbursement of funds for program purposes. Questioned Costs None. Recommendation We recommend that the Office develop and implement written policies and procedures relating to advancing funds to subrecipients to ensure that excess cash on hand at the subrecipient does not exceed 30 days and that its review over excess cash on hand is properly documented to provide evidence that it has been reviewed. View of Responsible Officials The State concurs in part with the premise of the findings identified, but it does not concur with the characterization of the Governor?s Office for Emergency Relief and Recovery (GOFERR), the process for authorizing the relevant subaward and relevant amendments, the nature of the subaward and amendments, or the recommended corrective action. Moreover, the full $49,250,000 identified in the finding was not provided to the subrecipient in one lump sum. The State was allocated $50,000,000 from U.S. Treasury for the purposes of designing and facilitating the State?s HAF program. The State received $5,000,000 from U.S. Treasury up front and received the remainder after approval of the State?s planned program. As a result, the State?s subrecipient received an initial subaward for administrative and planning purposes from within the initial $5,000,000 delivered to the State. The subrecipient was advanced only a portion of those initial funds and then was provided the remainder upon request and justification. A subsequent amendment to that subaward provided additional funds to the subrecipient as needed for the same purpose and as part of the U.S. Treasury required process of designing and then attaining approval for the State?s HAF program. The State ultimately received approval from U.S. Treasury for the State?s HAF program plan, which is a complex multi-faceted program that provides various forms of assistance to homeowners, and then received approval from State officials to launch the program. The State?s program is run entirely through a single subrecipient, New Hampshire Housing Finance Authority, which is the only entity of its kind as a statewide housing authority. This subrecipient facilitates a variety of larger-scale, federally funded housing programs. While developing the State?s HAF program and as it neared the launch date, the State began receiving preapplications through its subrecipient. Additionally, during this time, the State was facilitating its Emergency Rental Assistance (ERA) program, which has provided assistance to renters as opposed to homeowners and is facilitated by the same subrecipient of the State. Within the context of having received nearly 200 preapplications for the HAF program and witnessing a heavy and increasing demand in the rental assistance program, the decision was made to advance the remainder of the State?s HAF allocation ($45,000,000) to its subrecipient in order to provide prompt and adequate assistance, believing the program would experience high demand at the outset and funding shortfalls would be problematic for its success. Moreover, the amount of funds provided to the subrecipient was consistent with past advances to the same subrecipient under the ERA program, and as with prior delivery of funds, the subrecipient placed the funds in an appropriate account. However, demand for assistance did not unfold as anticipated due to the features of the program and the areas of need ultimately demonstrated by applicants after review and processing of initial applications. As part of the State?s monitoring protocols, and in part because of a lower initial expenditure rate than expected, the subrecipient began providing biweekly reports on the usage of funds, which the State has used as a measure of cash on hand. Moreover, the State also engages in standing, calendared, weekly calls with the subrecipient to discuss these reports. The State has provided documentation to support the process outlined above as well. Finally, as a result of the State?s remaining HAF allocation having already been provided to the subrecipient, the recommended corrective action is not feasible. However, the State acknowledges the need to more formally memorialize its review of the subrecipient?s cash on hand. As a result, the biweekly reports received and reviewed by the State will now include a specific section providing such information; review and discussion of that data will be incorporated into the weekly calls with the subrecipient, and the process and protocols will be documented in the State?s transaction processing memo for the program. Corrective Action Incorporation of cash on hand related data in biweekly reports received and reviewed by the State, documentation of that review as part of the weekly calls with subrecipient, and memorialization of the process and protocols in the State?s transaction processing memo for its HAF program. Anticipated Completion Date: Cash on hand data into biweekly reports and documentation of review said data as part of weekly calls with the subrecipient is being is actively being incorporated as of this response. The State will ensure that the transaction processing memo is updated with the requisite processes and protocols during the next update before the end of Q1 2023. Contact Persons: Chase Hagman, Lisa Cota-Robles, and Michele Zangri-Crean
Program: AL 12.401 ? National Guard Military Operations and Maintenance (O&M) Projects ? Cash Management & Reporting Grant Number & Year: Appendices ? W91243-20-2-1001, FFY 2020; W91243-21-2-1001, FFY 2021; W91243-21-2-1005, FFY 2021; W91243-21-2-1021, FFY 2021; W91243-22-2-1001, FFY 2022; W91243-22-2-1002, FFY 2022; W91243-22-2-1003, FFY 2022; W91243-22-2-1005, FFY 2022; W91243-22-2-1024, FFY 2022 Federal Grantor Agency: U.S. Department of Defense Criteria: Per 2 CFR ? 1128.100 and 2 CFR ? 1128.200 (January 1, 2022), the Department of Defense adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements set forth at 2 CFR parts 200.302, 200.303, and 200.305. Per 2 CFR ? 200.303 (January 1, 2022): 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. Title 2 CFR ? 200.302 (January 1, 2022) requires financial management systems of the State sufficient to permit both the preparation of required reports and the tracing of funds to expenditures adequate to establish that the use of the funds was in accordance with applicable regulations. EnterpriseOne is the official accounting system for the State of Nebraska, and all expenditures are generated from it. Title 2 CFR ? 200.305(a) (January 1, 2022) states, in part, ?For states, payments are governed by Treasury-State Cash Management Improvement Act (CMIA) agreements and default procedures codified at 31 CFR part 205 . . . .? Title 31 CFR Part 205 (July 1, 2021) implements the Cash Management Improvement Act (CMIA) and requires State recipients to enter into agreements that document accepted funding techniques for Federal assistance programs. The CMIA Agreement between the State of Nebraska, Secretary of the Treasury, and U.S. Department of the Treasury, for the period July 1, 2021, through June 30, 2022, allows the program to request Federal funds in accordance with the monthly draw funding technique by which the amount requested shall be based on estimated costs to be incurred in the next month. Master Cooperative Agreement (October 2020), Article V ? Payment, Section 503, Payment by Advance Method, states, ?The advance payment method shall be according to procedures established in current PARC policy, NGR 5-1 Chapter 11 or successor CNGB I & M, and 2 CFR ?200.305.? National Guard Regulation (NGR) 5-1, National Guard Grants and Cooperative Agreements, Section 11-5, Advance Payment Method, Section (5), states in part, ?[T]he grantee agrees to minimize the time elapsing between the transfer of funds from the U.S. Treasury and their disbursement by the State. (no more than 45 days)?. NGR 5-1 was in effect during the entire audit period but has since been superseded by CNGBI 9101.00, which went into effect on January 27, 2023. Instructions for OMB Standard Form 270 (REV. 1/2016) includes the following for line 11a, ?Enter program outlays to date (net of refunds, rebates, and discounts), in the appropriate columns. For requests prepared on a cash basis, outlays are the sum of actual cash disbursements for goods and services, the amount of indirect expenses charged, the value of in- kind contributions applied, and the amount of cash advances and payments made to subcontractors and subrecipients.? A good internal control plan would include procedures to ensure that the time between the drawdown of Federal funds and disbursements are minimized and in compliance with State of Nebraska CMIA Agreement and National Guard Regulations. Condition: The Agency was not in compliance with the Federal cash management requirements during the fiscal year and did not properly report program outlays on the OMB Standard Form (SF) 270. A similar finding was noted in the prior audit. Repeat Finding: 2021-059 Questioned Costs: None Statistical Sample: No Context: We tested 25 drawdowns and noted the following: ? Fourteen drawdowns were not in compliance with NGR 5-1. Ten of the draws were expended from 46 to 334 calendar days after the drawdown of Federal funds. The other four draws had yet to be fully expended as of February 9, 2023. The table below provides a summary of the 14 draws: See Schedule of Findings and Questioned Costs for chart/table. ? In addition, four draws were not in compliance with CMIA Agreement requirements. Advance amounts were requested based on estimated costs to be incurred during the month covered by the requests. To determine the reasonableness of the estimates, the APA determined the time it took the Agency to expend amounts advanced (without consideration of any cash on hand). Four draws were expended between 64 and 110 days after the drawdown of Federal funds. ? For 24 of 25 SF 270?s tested, the Agency did not properly report total program outlays on the OMB SF-270 report. The Military reported the total drawdowns for the program to date, rather than actual cash disbursements, as total program outlays. The variance between what was reported and what should have been reported ranged from an underreporting of $56,356 to an overreporting of $2,310,585, with a net total overreporting of total program outlays by $10,983,232 for the 25 reports tested. Cause: Inadequate procedures for coding funds and estimating cash needs for the upcoming month. The Agency drew down funds from the wrong Federal program. The Agency has recorded expenditures for two capital construction projects dating back to December 2019. The Agency reports expenditures for the projects under the Military Construction program (AL 12.400), stating that the projects are Federally funded under AL 12.400. However, it drew down funds for the projects under AL 12.401. Regarding SF-270 reporting, the Agency thought that the report instructions requiring reporting of actual cash disbursements as total program outlays did not apply to it as an ?advance State? (a State that is authorized to request funds on an advance basis). Effect: The Agency is not in compliance with Federal cash management and reporting requirements, which could result in sanctions. Additionally, there is an increased risk for the loss of Federal funding. Recommendation: We recommend the Agency ensure that the amount of time between the Federal draw and the disbursement of funds by the State is minimized and in compliance with the State of Nebraska CMIA Agreement and National Guard Regulations. We also recommend the Agency report total program outlays in compliance with Federal requirements. Management Response: The United States Property and Fiscal Office (USPFO) concurs with the recommendation.
Finding Reference Number: 2022-027 NH Department of Energy Low Income Home Energy Assistance and COVID-19 Low Income Home Energy Assistance (Assistance Listing #93.568) Federal Award Numbers: 2001NHLEA, 2001NHLIE4, 2001NH5C3, 2101NHLIEA, 2101NHE5C6, 2201NHLIEA, 2101NHLIE4 Federal Award Year: 2020, 2021, 2022 U.S. Department of Health and Human Services Compliance Requirement: Cash Management Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: No Statistically Valid Sample: No Criteria U.S. Department of the Treasury (Treasury) regulations at 31 CFR section 204 part 205 implement the Cash Management Act of 1990 (CMIA). Subpart A of those regulations requires state recipients to enter into Treasury-State Agreements that prescribe specific methods of drawing down federal funds (funding techniques) for federal programs listed in the Catalog of Federal Domestic assistance that meet the funding threshold for a major federal program under the CMIA. Treasury-State Agreements also specify the terms and conditions under which an interest liability would be incurred. Pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient (2 CFR section 200.305(b)(1)). Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testwork over performed over cash management related to the Low-Income Home Energy Assistance program, we noted the following: A. Under the State of New Hampshire?s Cash Management Agreement (CMIA), direct expenditures are to be drawn using the actual draw ? monthly technique. Under this technique, the funds are to be requested monthly based on actual costs incurred during that 1-month period. The funding technique is interest neutral. During our testwork over the cash draw process, we noted the following: a. For 5 of 7 cash draws selected for testwork, the New Hampshire Department of Energy (the Department) did not draw funds timely resulting in the cash draw to be delinquent. Each of the 4 cash draw covered multiple months of activity. b. For 1 of 7 cash draws selected for testwork, the Department drew funds down in advance as the cash draw covered 27 days only for the month of March 2022. We further noted, that during the month of March 2022, the Department completed an additional cash draw that covered 3 days of activity. As the clearance pattern within the CMIA agreement is interest neutral, there was no interest impact because of the cash draws not being performed timely. B. The Department advances payments to subrecipients to ensure that they have sufficient cash on hand to pay for benefit payments. The Department passed through $37,990,873 to subrecipients during the year ended June 30, 2022. During our testwork over compliance with cash management, we noted that for 1 of 3 subrecipients selected for testwork, the Department provided an advance payment to the subrecipient for programmatic expense and the advanced funds were not fully used by the subrecipient for approximately 5 months. The Department?s normal disbursement cycle of every 30 days. As such, it does not appear that the Department sufficiently minimized the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes. In addition to the above, we noted that for the same subrecipient, the advance memo to authorize the advance payment was not signed by the Program and Fiscal Manager as required by the Department?s policies and procedures. Cause The cause of the condition found was primarily due to insufficient resources to monitor and track cash draws to ensure they are performed timely in accordance with the clearance patten established within the CMIA agreement and to ensure that subrecipients either utilize advance funds timely or effectively evaluate the amount of funds they need on hand at the time of the advance payment. Effect The effect of the condition found is that the Department did not comply with the provisions of the CMIA as it relates to the timing of cash draws. In addition, subrecipients had excess cash on hand as the Department did not minimize the time elapsing between the transfer of federal funds to the subrecipient and their disbursement of funds for program purposes. As such the Department was not in compliance with 2 CFR section 200.305(b)(1). Questioned Costs None. Recommendation We recommend that the Department review its existing internal controls, policies, and procedures to ensure that all cash draws are performed timely and in accordance with the CMIA agreement. In addition, we recommend that the Department review its existing internal controls, policies and procedures relating to advancing funds to subrecipients to ensure that excess cash held by the subrecipients does not exceed 30 days. View of Responsible Officials Related to compliance with the CMIA, the Department of Energy acknowledges there were several instances where draws were not completed on a monthly basis for the prior month?s expenditures following the CMIA agreement in FY22. The Department of Energy has hired another staff person to complete business office grant-related tasks and will be reviewing and adjusting our policies and procedures if and where needed in the future. This staff person is still in training, therefore the completion date is not known at this time. Related to the timing of payments to subrecipients, due to staffing issues in both the Administrative and Fiscal offices, this recommendation is acknowledged and accepted. Support staff in both offices are being recruited and trained. This will ensure that adequate supervision and compliance of sub-recipient cash advances procedures are followed. Anticipated Completion Date: Ongoing Contact Person: Jane Lemire Business Administrator IV (PT) and Eileen Smiglowski, NH LIHEAP Administrator
Finding Reference Number: 2022-027 NH Department of Energy Low Income Home Energy Assistance and COVID-19 Low Income Home Energy Assistance (Assistance Listing #93.568) Federal Award Numbers: 2001NHLEA, 2001NHLIE4, 2001NH5C3, 2101NHLIEA, 2101NHE5C6, 2201NHLIEA, 2101NHLIE4 Federal Award Year: 2020, 2021, 2022 U.S. Department of Health and Human Services Compliance Requirement: Cash Management Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: No Statistically Valid Sample: No Criteria U.S. Department of the Treasury (Treasury) regulations at 31 CFR section 204 part 205 implement the Cash Management Act of 1990 (CMIA). Subpart A of those regulations requires state recipients to enter into Treasury-State Agreements that prescribe specific methods of drawing down federal funds (funding techniques) for federal programs listed in the Catalog of Federal Domestic assistance that meet the funding threshold for a major federal program under the CMIA. Treasury-State Agreements also specify the terms and conditions under which an interest liability would be incurred. Pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient (2 CFR section 200.305(b)(1)). Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testwork over performed over cash management related to the Low-Income Home Energy Assistance program, we noted the following: A. Under the State of New Hampshire?s Cash Management Agreement (CMIA), direct expenditures are to be drawn using the actual draw ? monthly technique. Under this technique, the funds are to be requested monthly based on actual costs incurred during that 1-month period. The funding technique is interest neutral. During our testwork over the cash draw process, we noted the following: a. For 5 of 7 cash draws selected for testwork, the New Hampshire Department of Energy (the Department) did not draw funds timely resulting in the cash draw to be delinquent. Each of the 4 cash draw covered multiple months of activity. b. For 1 of 7 cash draws selected for testwork, the Department drew funds down in advance as the cash draw covered 27 days only for the month of March 2022. We further noted, that during the month of March 2022, the Department completed an additional cash draw that covered 3 days of activity. As the clearance pattern within the CMIA agreement is interest neutral, there was no interest impact because of the cash draws not being performed timely. B. The Department advances payments to subrecipients to ensure that they have sufficient cash on hand to pay for benefit payments. The Department passed through $37,990,873 to subrecipients during the year ended June 30, 2022. During our testwork over compliance with cash management, we noted that for 1 of 3 subrecipients selected for testwork, the Department provided an advance payment to the subrecipient for programmatic expense and the advanced funds were not fully used by the subrecipient for approximately 5 months. The Department?s normal disbursement cycle of every 30 days. As such, it does not appear that the Department sufficiently minimized the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes. In addition to the above, we noted that for the same subrecipient, the advance memo to authorize the advance payment was not signed by the Program and Fiscal Manager as required by the Department?s policies and procedures. Cause The cause of the condition found was primarily due to insufficient resources to monitor and track cash draws to ensure they are performed timely in accordance with the clearance patten established within the CMIA agreement and to ensure that subrecipients either utilize advance funds timely or effectively evaluate the amount of funds they need on hand at the time of the advance payment. Effect The effect of the condition found is that the Department did not comply with the provisions of the CMIA as it relates to the timing of cash draws. In addition, subrecipients had excess cash on hand as the Department did not minimize the time elapsing between the transfer of federal funds to the subrecipient and their disbursement of funds for program purposes. As such the Department was not in compliance with 2 CFR section 200.305(b)(1). Questioned Costs None. Recommendation We recommend that the Department review its existing internal controls, policies, and procedures to ensure that all cash draws are performed timely and in accordance with the CMIA agreement. In addition, we recommend that the Department review its existing internal controls, policies and procedures relating to advancing funds to subrecipients to ensure that excess cash held by the subrecipients does not exceed 30 days. View of Responsible Officials Related to compliance with the CMIA, the Department of Energy acknowledges there were several instances where draws were not completed on a monthly basis for the prior month?s expenditures following the CMIA agreement in FY22. The Department of Energy has hired another staff person to complete business office grant-related tasks and will be reviewing and adjusting our policies and procedures if and where needed in the future. This staff person is still in training, therefore the completion date is not known at this time. Related to the timing of payments to subrecipients, due to staffing issues in both the Administrative and Fiscal offices, this recommendation is acknowledged and accepted. Support staff in both offices are being recruited and trained. This will ensure that adequate supervision and compliance of sub-recipient cash advances procedures are followed. Anticipated Completion Date: Ongoing Contact Person: Jane Lemire Business Administrator IV (PT) and Eileen Smiglowski, NH LIHEAP Administrator
Finding 2022-003 Information on the federal program: Subject: Special Education Cluster ? Internal Controls Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Cash Management Audit Finding: Material Weakness, Modified Opinion Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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). . . ." For grants and cooperative agreements to non-federal entities that are paid on a reimbursement basis, supporting documentation shows that the costs for which reimbursement was requested were paid prior to the date of the reimbursement request. Pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient (2 CFR section 200.305(b)(1)). Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Cash Management compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with cash management for reimbursement grants. The School Corporation did not have a design control in place to ensure that service provider invoices were paid prior to the submitting reimbursements to the Indiana Department of Education (IDOE). Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Questioned Costs: There were no questioned costs identified. Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider, which totaled $1,109,356 for the audit period. For all invoices during the audit period, the School Corporation submitted and received reimbursement from the IDOE prior to paying the service provider, and then the School Corporation remitted payment to the service provider. In addition, the School Corporation only remitted 95% of the invoice to the service provider and held back 5% of the invoice, which management acknowledged was in error. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation implement procedures to ensure the invoices are paid before submitting draw requests and receiving funds from IDOE. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-003 Information on the federal program: Subject: Special Education Cluster ? Internal Controls Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Cash Management Audit Finding: Material Weakness, Modified Opinion Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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). . . ." For grants and cooperative agreements to non-federal entities that are paid on a reimbursement basis, supporting documentation shows that the costs for which reimbursement was requested were paid prior to the date of the reimbursement request. Pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient (2 CFR section 200.305(b)(1)). Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Cash Management compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with cash management for reimbursement grants. The School Corporation did not have a design control in place to ensure that service provider invoices were paid prior to the submitting reimbursements to the Indiana Department of Education (IDOE). Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Questioned Costs: There were no questioned costs identified. Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider, which totaled $1,109,356 for the audit period. For all invoices during the audit period, the School Corporation submitted and received reimbursement from the IDOE prior to paying the service provider, and then the School Corporation remitted payment to the service provider. In addition, the School Corporation only remitted 95% of the invoice to the service provider and held back 5% of the invoice, which management acknowledged was in error. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation implement procedures to ensure the invoices are paid before submitting draw requests and receiving funds from IDOE. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-003 Information on the federal program: Subject: Special Education Cluster ? Internal Controls Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Cash Management Audit Finding: Material Weakness, Modified Opinion Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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). . . ." For grants and cooperative agreements to non-federal entities that are paid on a reimbursement basis, supporting documentation shows that the costs for which reimbursement was requested were paid prior to the date of the reimbursement request. Pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient (2 CFR section 200.305(b)(1)). Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Cash Management compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with cash management for reimbursement grants. The School Corporation did not have a design control in place to ensure that service provider invoices were paid prior to the submitting reimbursements to the Indiana Department of Education (IDOE). Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Questioned Costs: There were no questioned costs identified. Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider, which totaled $1,109,356 for the audit period. For all invoices during the audit period, the School Corporation submitted and received reimbursement from the IDOE prior to paying the service provider, and then the School Corporation remitted payment to the service provider. In addition, the School Corporation only remitted 95% of the invoice to the service provider and held back 5% of the invoice, which management acknowledged was in error. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation implement procedures to ensure the invoices are paid before submitting draw requests and receiving funds from IDOE. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
2022-001: Procurement Policy and Procedures Condition: Several purchases were made in excess of the micro purchase threshold ($10,000). The Organization could not provide documentation to show they obtained quotes, or the reason quotes were not obtained, or if they gave preference to minority or women-owned businesses. Cause: The Organization has not established a written procurement policy. Criteria: The Code of Federal Regulations requires that entities receiving federal funding have a written procurement policy. The required elements of the procurement policy are detailed out in the Electronic Code of Federal Regulations (eCFR) under Title 2, Subtitle A, Part 200, Subpart D, 200.317 thru 200.327. Several other areas require written policies: financial management (200.302), federal payment (200.305), compensation-personal services (200.430), compensation-fringe benefits (200.431), relocation costs of employees (200.464), and travel costs (200.475). Effect: Lack of such policies increases the risk of purchasing items at higher prices than may have been necessary, increases the risk of limiting competition, and increases the risk of waste and abuse. Perspective Information: The need for a procurement policy was brought to the CEO's attention in the fall of 2021. The CEO does believe the spirit of the procurement requirements were met. Recommendations: We recommend quotes are obtained whenever possible when purchases are expected to be between $10,000 and $250,000. If purchases are to equal or exceed $250,000, the proper bidding procedures should be followed. Bidding procedures, quotes, and efforts to give preference to minority or women-owned businesses should be documented, including documenting if bids or quotes could not be obtained or the reasons why bids or quotes were not obtained. We also recommend a procurement policy is established as soon as possible and an individual is assigned to monitor the implementation of the policy. Views of Responsible Officials and Planned Corrective Actions: The Club agrees with this finding. Their intent is to create and implement a procurement policy that complies with the Code of Federal Regulations as soon as possible and add the proper documentation for purchases exceeding the micro purchase threshold beginning with fiscal year 2023. See Corrective Action Plan.
2022-001: Procurement Policy and Procedures Condition: Several purchases were made in excess of the micro purchase threshold ($10,000). The Organization could not provide documentation to show they obtained quotes, or the reason quotes were not obtained, or if they gave preference to minority or women-owned businesses. Cause: The Organization has not established a written procurement policy. Criteria: The Code of Federal Regulations requires that entities receiving federal funding have a written procurement policy. The required elements of the procurement policy are detailed out in the Electronic Code of Federal Regulations (eCFR) under Title 2, Subtitle A, Part 200, Subpart D, 200.317 thru 200.327. Several other areas require written policies: financial management (200.302), federal payment (200.305), compensation-personal services (200.430), compensation-fringe benefits (200.431), relocation costs of employees (200.464), and travel costs (200.475). Effect: Lack of such policies increases the risk of purchasing items at higher prices than may have been necessary, increases the risk of limiting competition, and increases the risk of waste and abuse. Perspective Information: The need for a procurement policy was brought to the CEO's attention in the fall of 2021. The CEO does believe the spirit of the procurement requirements were met. Recommendations: We recommend quotes are obtained whenever possible when purchases are expected to be between $10,000 and $250,000. If purchases are to equal or exceed $250,000, the proper bidding procedures should be followed. Bidding procedures, quotes, and efforts to give preference to minority or women-owned businesses should be documented, including documenting if bids or quotes could not be obtained or the reasons why bids or quotes were not obtained. We also recommend a procurement policy is established as soon as possible and an individual is assigned to monitor the implementation of the policy. Views of Responsible Officials and Planned Corrective Actions: The Club agrees with this finding. Their intent is to create and implement a procurement policy that complies with the Code of Federal Regulations as soon as possible and add the proper documentation for purchases exceeding the micro purchase threshold beginning with fiscal year 2023. See Corrective Action Plan.
2022-001: Procurement Policy and Procedures Condition: Several purchases were made in excess of the micro purchase threshold ($10,000). The Organization could not provide documentation to show they obtained quotes, or the reason quotes were not obtained, or if they gave preference to minority or women-owned businesses. Cause: The Organization has not established a written procurement policy. Criteria: The Code of Federal Regulations requires that entities receiving federal funding have a written procurement policy. The required elements of the procurement policy are detailed out in the Electronic Code of Federal Regulations (eCFR) under Title 2, Subtitle A, Part 200, Subpart D, 200.317 thru 200.327. Several other areas require written policies: financial management (200.302), federal payment (200.305), compensation-personal services (200.430), compensation-fringe benefits (200.431), relocation costs of employees (200.464), and travel costs (200.475). Effect: Lack of such policies increases the risk of purchasing items at higher prices than may have been necessary, increases the risk of limiting competition, and increases the risk of waste and abuse. Perspective Information: The need for a procurement policy was brought to the CEO's attention in the fall of 2021. The CEO does believe the spirit of the procurement requirements were met. Recommendations: We recommend quotes are obtained whenever possible when purchases are expected to be between $10,000 and $250,000. If purchases are to equal or exceed $250,000, the proper bidding procedures should be followed. Bidding procedures, quotes, and efforts to give preference to minority or women-owned businesses should be documented, including documenting if bids or quotes could not be obtained or the reasons why bids or quotes were not obtained. We also recommend a procurement policy is established as soon as possible and an individual is assigned to monitor the implementation of the policy. Views of Responsible Officials and Planned Corrective Actions: The Club agrees with this finding. Their intent is to create and implement a procurement policy that complies with the Code of Federal Regulations as soon as possible and add the proper documentation for purchases exceeding the micro purchase threshold beginning with fiscal year 2023. See Corrective Action Plan.
Information on the federal program ? Education Stabilization Fund (Higher Education Emergency Relief Funds), 84.425E and 84.425F Criteria or specific requirement ? The College is responsible for minimizing the time elapsed between the transfer of funds from the Department of Education (ED) and disbursement of those funds for program costs. (2 CFR Section 200.305(b)). The Certification and Funding Agreements require that the Student Aid Portion (84.425E) should be disbursed within fifteen calendar days of the drawdown and the Institutional Aid Portion (84.425F) should be disbursed within three calendar days from drawdown. Condition ? The College drew down funding for the Student Aid Portion in November 2021. The majority of funds were disbursed timely, in November 2021, but a portion of the funds were not disbursed until November 2022. Questioned costs ? None ? nonmonetary finding. Context ? Based on testing of drawdowns and disbursements, the Student Aid Portion was not disbursed within the fifteen-day requirement. Effect ? The College did not disburse funds timely. Cause ? For the portion of funds not disbursed timely, the College had established a plan for students to request Higher Education Emergency Relief Funds. In anticipation of many requests that would result in disbursing all amounts timely, the College drew down the entire amount of the student portion of the Higher Education Emergency Relief Funds awarded under the American Rescue Plan. The number of students requesting funds was less than the College anticipated and the College did not have enough time to create a plan to disburse the remaining funds timely. Identification as a repeat finding, if applicable ? N/A Recommendation ? We recommend the College adopt the reimbursement method of cash management for all federal funding.
Information on the federal program ? Education Stabilization Fund (Higher Education Emergency Relief Funds), 84.425E and 84.425F Criteria or specific requirement ? The College is responsible for minimizing the time elapsed between the transfer of funds from the Department of Education (ED) and disbursement of those funds for program costs. (2 CFR Section 200.305(b)). The Certification and Funding Agreements require that the Student Aid Portion (84.425E) should be disbursed within fifteen calendar days of the drawdown and the Institutional Aid Portion (84.425F) should be disbursed within three calendar days from drawdown. Condition ? The College drew down funding for the Student Aid Portion in November 2021. The majority of funds were disbursed timely, in November 2021, but a portion of the funds were not disbursed until November 2022. Questioned costs ? None ? nonmonetary finding. Context ? Based on testing of drawdowns and disbursements, the Student Aid Portion was not disbursed within the fifteen-day requirement. Effect ? The College did not disburse funds timely. Cause ? For the portion of funds not disbursed timely, the College had established a plan for students to request Higher Education Emergency Relief Funds. In anticipation of many requests that would result in disbursing all amounts timely, the College drew down the entire amount of the student portion of the Higher Education Emergency Relief Funds awarded under the American Rescue Plan. The number of students requesting funds was less than the College anticipated and the College did not have enough time to create a plan to disburse the remaining funds timely. Identification as a repeat finding, if applicable ? N/A Recommendation ? We recommend the College adopt the reimbursement method of cash management for all federal funding.
FINDING 2022-011 Subject: Special Education Cluster (IDEA) - Cash Management, Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 21611-138-PN01, 21619-138-PN01, 22611-138-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Cash Management, Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management and the Reporting compliance requirements. The School Corporation had not established an effective system of internal controls to ensure that proper documentation was retained for audit. The School Corporation was unable to provide supporting documentation for 12 of the 15 reimbursement requests tested. Due to the lack of documentation, we were unable to verify the amounts reported on the reimbursement requests to the School Corporation's records. In addition, we were unable to determine if program funds were expended prior to requesting reimbursement. INDIANA STATE BOARD OF ACCOUNTS 43 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of internal controls and failure to retain supporting documentation 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 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 2 CFR 200.334 (Revised Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.305(b) (Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.305(b) (Revised Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . INDIANA STATE BOARD OF ACCOUNTS 44 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.302(b) (Uniform Guidance) 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 ?? 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) 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." Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, with the grant agreement and the Cash Management and the Reporting compliance requirements. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with compliance requirements listed above. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure documentation will be maintained and made available for audit and comply with the grant agreement and the Cash Management and the Reporting compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-011 Subject: Special Education Cluster (IDEA) - Cash Management, Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 21611-138-PN01, 21619-138-PN01, 22611-138-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Cash Management, Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management and the Reporting compliance requirements. The School Corporation had not established an effective system of internal controls to ensure that proper documentation was retained for audit. The School Corporation was unable to provide supporting documentation for 12 of the 15 reimbursement requests tested. Due to the lack of documentation, we were unable to verify the amounts reported on the reimbursement requests to the School Corporation's records. In addition, we were unable to determine if program funds were expended prior to requesting reimbursement. INDIANA STATE BOARD OF ACCOUNTS 43 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of internal controls and failure to retain supporting documentation 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 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 2 CFR 200.334 (Revised Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.305(b) (Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.305(b) (Revised Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . INDIANA STATE BOARD OF ACCOUNTS 44 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.302(b) (Uniform Guidance) 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 ?? 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) 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." Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, with the grant agreement and the Cash Management and the Reporting compliance requirements. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with compliance requirements listed above. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure documentation will be maintained and made available for audit and comply with the grant agreement and the Cash Management and the Reporting compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-011 Subject: Special Education Cluster (IDEA) - Cash Management, Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 21611-138-PN01, 21619-138-PN01, 22611-138-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Cash Management, Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management and the Reporting compliance requirements. The School Corporation had not established an effective system of internal controls to ensure that proper documentation was retained for audit. The School Corporation was unable to provide supporting documentation for 12 of the 15 reimbursement requests tested. Due to the lack of documentation, we were unable to verify the amounts reported on the reimbursement requests to the School Corporation's records. In addition, we were unable to determine if program funds were expended prior to requesting reimbursement. INDIANA STATE BOARD OF ACCOUNTS 43 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of internal controls and failure to retain supporting documentation 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 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 2 CFR 200.334 (Revised Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.305(b) (Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.305(b) (Revised Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . INDIANA STATE BOARD OF ACCOUNTS 44 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.302(b) (Uniform Guidance) 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 ?? 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) 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." Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, with the grant agreement and the Cash Management and the Reporting compliance requirements. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with compliance requirements listed above. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure documentation will be maintained and made available for audit and comply with the grant agreement and the Cash Management and the Reporting compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-006 Subject: Title I Grants to Local Educational Agencies - Cash Management and Reporting Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Cash Management, Reporting Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding related to Reporting from the immediately prior audit report. The prior audit finding number was 2020-007. INDIANA STATE BOARD OF ACCOUNTS 32 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management and the Reporting compliance requirements. The School Corporation filed the required special reports with the Indiana Department of Education; however, none of the reports were supported by the School Corporation's records. Although the Title I Director reviewed the requests for reimbursement and the Final Expenditure Reports, the reviews did not ensure that the reports agreed to the School Corporation's financial records. The 2019-2020 and 2020-2021 Final Expenditure Reports and the four reimbursement requests tested could not be traced to the School Corporation's records. 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 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) (Uniform Guidance) states in part: . . . "The financial management system of each non-Federal entity must provide for the following: INDIANA STATE BOARD OF ACCOUNTS 33 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 ?? 200.327 Financial reporting. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) 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." 2 CFR 200.305(b) (Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.305(b) (Revised Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." Cause Management had not established an effective system of internal controls that would have ensured compliance with requirements related to the Cash Management and the Reporting compliance requirements. INDIANA STATE BOARD OF ACCOUNTS 34 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure documentation be maintained and made available for audit related to the grant agreement and the Cash Management and the Reporting compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-006 Subject: Title I Grants to Local Educational Agencies - Cash Management and Reporting Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Cash Management, Reporting Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding related to Reporting from the immediately prior audit report. The prior audit finding number was 2020-007. INDIANA STATE BOARD OF ACCOUNTS 32 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management and the Reporting compliance requirements. The School Corporation filed the required special reports with the Indiana Department of Education; however, none of the reports were supported by the School Corporation's records. Although the Title I Director reviewed the requests for reimbursement and the Final Expenditure Reports, the reviews did not ensure that the reports agreed to the School Corporation's financial records. The 2019-2020 and 2020-2021 Final Expenditure Reports and the four reimbursement requests tested could not be traced to the School Corporation's records. 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 200.333 (Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) (Uniform Guidance) states in part: . . . "The financial management system of each non-Federal entity must provide for the following: INDIANA STATE BOARD OF ACCOUNTS 33 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 ?? 200.327 Financial reporting. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) 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." 2 CFR 200.305(b) (Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.305(b) (Revised Uniform Guidance) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." Cause Management had not established an effective system of internal controls that would have ensured compliance with requirements related to the Cash Management and the Reporting compliance requirements. INDIANA STATE BOARD OF ACCOUNTS 34 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure documentation be maintained and made available for audit related to the grant agreement and the Cash Management and the Reporting compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-014 Subject: COVID-19 - Education Stabilization Fund - Cash Management 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: Cash Management Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management compliance requirement. The School Corporation requested reimbursement based off a calculation with the budgeted line items instead of actual grant expenses. For 19 of 20 reimbursement requests tested, the School Corporation was unable to provide adequate supporting documentation. Due to the lack of supporting documentation, it was not possible to determine if grant payments were reimbursements of expenditures or advance payments. 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: INDIANA STATE BOARD OF ACCOUNTS 54 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 200.305(b) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." 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. . . ." Cause Management had not designed nor implemented a system of internal controls that would have ensured compliance or that supporting documentation would have been maintained and available for audit related to the Cash Management compliance requirement. Effect The failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Cash Management compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grant agreement and the Cash Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-014 Subject: COVID-19 - Education Stabilization Fund - Cash Management 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: Cash Management Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management compliance requirement. The School Corporation requested reimbursement based off a calculation with the budgeted line items instead of actual grant expenses. For 19 of 20 reimbursement requests tested, the School Corporation was unable to provide adequate supporting documentation. Due to the lack of supporting documentation, it was not possible to determine if grant payments were reimbursements of expenditures or advance payments. 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: INDIANA STATE BOARD OF ACCOUNTS 54 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 200.305(b) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." 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. . . ." Cause Management had not designed nor implemented a system of internal controls that would have ensured compliance or that supporting documentation would have been maintained and available for audit related to the Cash Management compliance requirement. Effect The failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Cash Management compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grant agreement and the Cash Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-014 Subject: COVID-19 - Education Stabilization Fund - Cash Management 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: Cash Management Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management compliance requirement. The School Corporation requested reimbursement based off a calculation with the budgeted line items instead of actual grant expenses. For 19 of 20 reimbursement requests tested, the School Corporation was unable to provide adequate supporting documentation. Due to the lack of supporting documentation, it was not possible to determine if grant payments were reimbursements of expenditures or advance payments. 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: INDIANA STATE BOARD OF ACCOUNTS 54 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 200.305(b) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." 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. . . ." Cause Management had not designed nor implemented a system of internal controls that would have ensured compliance or that supporting documentation would have been maintained and available for audit related to the Cash Management compliance requirement. Effect The failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Cash Management compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grant agreement and the Cash Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-014 Subject: COVID-19 - Education Stabilization Fund - Cash Management 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: Cash Management Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management compliance requirement. The School Corporation requested reimbursement based off a calculation with the budgeted line items instead of actual grant expenses. For 19 of 20 reimbursement requests tested, the School Corporation was unable to provide adequate supporting documentation. Due to the lack of supporting documentation, it was not possible to determine if grant payments were reimbursements of expenditures or advance payments. 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: INDIANA STATE BOARD OF ACCOUNTS 54 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 200.305(b) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." 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. . . ." Cause Management had not designed nor implemented a system of internal controls that would have ensured compliance or that supporting documentation would have been maintained and available for audit related to the Cash Management compliance requirement. Effect The failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Cash Management compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grant agreement and the Cash Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
2022-003: Noncompliance with Cash Management Department of Labor WIOA Cluster AL #17.258 WIOA Adult Program AL #17.259 WIOA Youth Activities AL #17.278 WIOA Dislocated Worker Formula Grants Department of Treasury AL# 21.019 Coronavirus Relief Fund Condition: Cash draws from WIOA Cluster and Coronavirus Relief Fund grants exceeded the amount needed to cover allowable costs. Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Cause: Staffing issues resulted in funds being overdrawn and inaccuracies in reconciling the State of Indiana Department of Workforce Development?s system and the general ledger. Effect: Approximately $286,000 of WIOA Cluster funds and $94,000 of Coronavirus Relief Funds were drawn in excess of allowable costs incurred. Recommendation: Management needs to work with the State of Indiana Department of Workforce Development to refund the overdrawn funds or apply the funds to allowable costs in the upcoming fiscal year. Views of Responsible Officials and Planned Corrective Actions: Staffing changes have occurred, and the fiscal management duties have been outsourced to a third party which has experience with Workforce Boards and related grants. The issues are being addressed with IN DWD.
2022-003: Noncompliance with Cash Management Department of Labor WIOA Cluster AL #17.258 WIOA Adult Program AL #17.259 WIOA Youth Activities AL #17.278 WIOA Dislocated Worker Formula Grants Department of Treasury AL# 21.019 Coronavirus Relief Fund Condition: Cash draws from WIOA Cluster and Coronavirus Relief Fund grants exceeded the amount needed to cover allowable costs. Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Cause: Staffing issues resulted in funds being overdrawn and inaccuracies in reconciling the State of Indiana Department of Workforce Development?s system and the general ledger. Effect: Approximately $286,000 of WIOA Cluster funds and $94,000 of Coronavirus Relief Funds were drawn in excess of allowable costs incurred. Recommendation: Management needs to work with the State of Indiana Department of Workforce Development to refund the overdrawn funds or apply the funds to allowable costs in the upcoming fiscal year. Views of Responsible Officials and Planned Corrective Actions: Staffing changes have occurred, and the fiscal management duties have been outsourced to a third party which has experience with Workforce Boards and related grants. The issues are being addressed with IN DWD.
2022-003: Noncompliance with Cash Management Department of Labor WIOA Cluster AL #17.258 WIOA Adult Program AL #17.259 WIOA Youth Activities AL #17.278 WIOA Dislocated Worker Formula Grants Department of Treasury AL# 21.019 Coronavirus Relief Fund Condition: Cash draws from WIOA Cluster and Coronavirus Relief Fund grants exceeded the amount needed to cover allowable costs. Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Cause: Staffing issues resulted in funds being overdrawn and inaccuracies in reconciling the State of Indiana Department of Workforce Development?s system and the general ledger. Effect: Approximately $286,000 of WIOA Cluster funds and $94,000 of Coronavirus Relief Funds were drawn in excess of allowable costs incurred. Recommendation: Management needs to work with the State of Indiana Department of Workforce Development to refund the overdrawn funds or apply the funds to allowable costs in the upcoming fiscal year. Views of Responsible Officials and Planned Corrective Actions: Staffing changes have occurred, and the fiscal management duties have been outsourced to a third party which has experience with Workforce Boards and related grants. The issues are being addressed with IN DWD.
2022-003: Noncompliance with Cash Management Department of Labor WIOA Cluster AL #17.258 WIOA Adult Program AL #17.259 WIOA Youth Activities AL #17.278 WIOA Dislocated Worker Formula Grants Department of Treasury AL# 21.019 Coronavirus Relief Fund Condition: Cash draws from WIOA Cluster and Coronavirus Relief Fund grants exceeded the amount needed to cover allowable costs. Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Cause: Staffing issues resulted in funds being overdrawn and inaccuracies in reconciling the State of Indiana Department of Workforce Development?s system and the general ledger. Effect: Approximately $286,000 of WIOA Cluster funds and $94,000 of Coronavirus Relief Funds were drawn in excess of allowable costs incurred. Recommendation: Management needs to work with the State of Indiana Department of Workforce Development to refund the overdrawn funds or apply the funds to allowable costs in the upcoming fiscal year. Views of Responsible Officials and Planned Corrective Actions: Staffing changes have occurred, and the fiscal management duties have been outsourced to a third party which has experience with Workforce Boards and related grants. The issues are being addressed with IN DWD.
2022-003: Noncompliance with Cash Management Department of Labor WIOA Cluster AL #17.258 WIOA Adult Program AL #17.259 WIOA Youth Activities AL #17.278 WIOA Dislocated Worker Formula Grants Department of Treasury AL# 21.019 Coronavirus Relief Fund Condition: Cash draws from WIOA Cluster and Coronavirus Relief Fund grants exceeded the amount needed to cover allowable costs. Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Cause: Staffing issues resulted in funds being overdrawn and inaccuracies in reconciling the State of Indiana Department of Workforce Development?s system and the general ledger. Effect: Approximately $286,000 of WIOA Cluster funds and $94,000 of Coronavirus Relief Funds were drawn in excess of allowable costs incurred. Recommendation: Management needs to work with the State of Indiana Department of Workforce Development to refund the overdrawn funds or apply the funds to allowable costs in the upcoming fiscal year. Views of Responsible Officials and Planned Corrective Actions: Staffing changes have occurred, and the fiscal management duties have been outsourced to a third party which has experience with Workforce Boards and related grants. The issues are being addressed with IN DWD.
2022-003: Noncompliance with Cash Management Department of Labor WIOA Cluster AL #17.258 WIOA Adult Program AL #17.259 WIOA Youth Activities AL #17.278 WIOA Dislocated Worker Formula Grants Department of Treasury AL# 21.019 Coronavirus Relief Fund Condition: Cash draws from WIOA Cluster and Coronavirus Relief Fund grants exceeded the amount needed to cover allowable costs. Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Cause: Staffing issues resulted in funds being overdrawn and inaccuracies in reconciling the State of Indiana Department of Workforce Development?s system and the general ledger. Effect: Approximately $286,000 of WIOA Cluster funds and $94,000 of Coronavirus Relief Funds were drawn in excess of allowable costs incurred. Recommendation: Management needs to work with the State of Indiana Department of Workforce Development to refund the overdrawn funds or apply the funds to allowable costs in the upcoming fiscal year. Views of Responsible Officials and Planned Corrective Actions: Staffing changes have occurred, and the fiscal management duties have been outsourced to a third party which has experience with Workforce Boards and related grants. The issues are being addressed with IN DWD.
2022-003: Noncompliance with Cash Management Department of Labor WIOA Cluster AL #17.258 WIOA Adult Program AL #17.259 WIOA Youth Activities AL #17.278 WIOA Dislocated Worker Formula Grants Department of Treasury AL# 21.019 Coronavirus Relief Fund Condition: Cash draws from WIOA Cluster and Coronavirus Relief Fund grants exceeded the amount needed to cover allowable costs. Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Cause: Staffing issues resulted in funds being overdrawn and inaccuracies in reconciling the State of Indiana Department of Workforce Development?s system and the general ledger. Effect: Approximately $286,000 of WIOA Cluster funds and $94,000 of Coronavirus Relief Funds were drawn in excess of allowable costs incurred. Recommendation: Management needs to work with the State of Indiana Department of Workforce Development to refund the overdrawn funds or apply the funds to allowable costs in the upcoming fiscal year. Views of Responsible Officials and Planned Corrective Actions: Staffing changes have occurred, and the fiscal management duties have been outsourced to a third party which has experience with Workforce Boards and related grants. The issues are being addressed with IN DWD.
2022-003: Noncompliance with Cash Management Department of Labor WIOA Cluster AL #17.258 WIOA Adult Program AL #17.259 WIOA Youth Activities AL #17.278 WIOA Dislocated Worker Formula Grants Department of Treasury AL# 21.019 Coronavirus Relief Fund Condition: Cash draws from WIOA Cluster and Coronavirus Relief Fund grants exceeded the amount needed to cover allowable costs. Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Cause: Staffing issues resulted in funds being overdrawn and inaccuracies in reconciling the State of Indiana Department of Workforce Development?s system and the general ledger. Effect: Approximately $286,000 of WIOA Cluster funds and $94,000 of Coronavirus Relief Funds were drawn in excess of allowable costs incurred. Recommendation: Management needs to work with the State of Indiana Department of Workforce Development to refund the overdrawn funds or apply the funds to allowable costs in the upcoming fiscal year. Views of Responsible Officials and Planned Corrective Actions: Staffing changes have occurred, and the fiscal management duties have been outsourced to a third party which has experience with Workforce Boards and related grants. The issues are being addressed with IN DWD.
2022-003: Noncompliance with Cash Management Department of Labor WIOA Cluster AL #17.258 WIOA Adult Program AL #17.259 WIOA Youth Activities AL #17.278 WIOA Dislocated Worker Formula Grants Department of Treasury AL# 21.019 Coronavirus Relief Fund Condition: Cash draws from WIOA Cluster and Coronavirus Relief Fund grants exceeded the amount needed to cover allowable costs. Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Cause: Staffing issues resulted in funds being overdrawn and inaccuracies in reconciling the State of Indiana Department of Workforce Development?s system and the general ledger. Effect: Approximately $286,000 of WIOA Cluster funds and $94,000 of Coronavirus Relief Funds were drawn in excess of allowable costs incurred. Recommendation: Management needs to work with the State of Indiana Department of Workforce Development to refund the overdrawn funds or apply the funds to allowable costs in the upcoming fiscal year. Views of Responsible Officials and Planned Corrective Actions: Staffing changes have occurred, and the fiscal management duties have been outsourced to a third party which has experience with Workforce Boards and related grants. The issues are being addressed with IN DWD.
Child Nutrition Cluster ?School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-005 ? Significant Deficiency in Controls over Compliance and Compliance Finding: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding 2021-006 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management, procurement and compensation are in need of adoption and enhancement to meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: The Catholic Secondary Schools of the Diocese of Grand Rapids have limited written policies and procedures that are applicable to federal awards and address the direct and material compliance matters important to the major federal program. In addition, there are unique policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that are relevant to the Schools? federal programs. Recommendations: The Catholic Secondary Schools of the Diocese of Grand Rapids should adopt the following written policies and updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Schools ensure compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 ? 200.326) The Schools must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320. ? Policy Guide (2 CFR 200.400) In summary, the Schools must have written policies that document the efficient and effective administration of federal awards through sound management practices. The Schools have the primary responsibility for employing whatever form of sound organization and management techniques may be necessary to assure proper and efficient administration of the federal awards. The accounting practices must be consistent with Uniform Guidance cost principles, support the accumulation of costs as required, and must provide for adequate documentation to support costs charged to the federal award. Views of Responsible Officials and Planned Corrective Actions: Child Nutrition Cluster ?School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-005 ? Significant Deficiency in Controls over Compliance and Compliance Finding: Administrative Requirements of Uniform Guidance ? Administrative Policies This is also a compliance finding, not just controls - UPDATED This is a repeat of prior year finding 2021-006 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management, procurement and compensation are in need of adoption and enhancement to meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: The Catholic Secondary Schools of the Diocese of Grand Rapids have limited written policies and procedures that are applicable to federal awards and address the direct and material compliance matters important to the major federal program. In addition, there are unique policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that are relevant to the Schools? federal programs. Recommendations: The Catholic Secondary Schools of the Diocese of Grand Rapids should adopt the following written policies and updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Schools ensure compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 ? 200.326) The Schools must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320. ? Policy Guide (2 CFR 200.400) In summary, the Schools must have written policies that document the efficient and effective administration of federal awards through sound management practices. The Schools have the primary responsibility for employing whatever form of sound organization and management techniques may be necessary to assure proper and efficient administration of the federal awards. The accounting practices must be consistent with Uniform Guidance cost principles, support the accumulation of costs as required, and must provide for adequate documentation to support costs charged to the federal award. Views of Responsible Officials and Planned Corrective Actions: We concur with the findings of the auditors. We have developed a plan to address the findings, and are actively working to implement that plan. The corrective action plan is attached to this report.
Child Nutrition Cluster ?School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-005 ? Significant Deficiency in Controls over Compliance and Compliance Finding: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding 2021-006 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management, procurement and compensation are in need of adoption and enhancement to meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: The Catholic Secondary Schools of the Diocese of Grand Rapids have limited written policies and procedures that are applicable to federal awards and address the direct and material compliance matters important to the major federal program. In addition, there are unique policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that are relevant to the Schools? federal programs. Recommendations: The Catholic Secondary Schools of the Diocese of Grand Rapids should adopt the following written policies and updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Schools ensure compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 ? 200.326) The Schools must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320. ? Policy Guide (2 CFR 200.400) In summary, the Schools must have written policies that document the efficient and effective administration of federal awards through sound management practices. The Schools have the primary responsibility for employing whatever form of sound organization and management techniques may be necessary to assure proper and efficient administration of the federal awards. The accounting practices must be consistent with Uniform Guidance cost principles, support the accumulation of costs as required, and must provide for adequate documentation to support costs charged to the federal award. Views of Responsible Officials and Planned Corrective Actions: Child Nutrition Cluster ?School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-005 ? Significant Deficiency in Controls over Compliance and Compliance Finding: Administrative Requirements of Uniform Guidance ? Administrative Policies This is also a compliance finding, not just controls - UPDATED This is a repeat of prior year finding 2021-006 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management, procurement and compensation are in need of adoption and enhancement to meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: The Catholic Secondary Schools of the Diocese of Grand Rapids have limited written policies and procedures that are applicable to federal awards and address the direct and material compliance matters important to the major federal program. In addition, there are unique policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that are relevant to the Schools? federal programs. Recommendations: The Catholic Secondary Schools of the Diocese of Grand Rapids should adopt the following written policies and updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Schools ensure compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 ? 200.326) The Schools must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320. ? Policy Guide (2 CFR 200.400) In summary, the Schools must have written policies that document the efficient and effective administration of federal awards through sound management practices. The Schools have the primary responsibility for employing whatever form of sound organization and management techniques may be necessary to assure proper and efficient administration of the federal awards. The accounting practices must be consistent with Uniform Guidance cost principles, support the accumulation of costs as required, and must provide for adequate documentation to support costs charged to the federal award. Views of Responsible Officials and Planned Corrective Actions: We concur with the findings of the auditors. We have developed a plan to address the findings, and are actively working to implement that plan. The corrective action plan is attached to this report.
Rural Behavioral Health Workforce Coordinating Centers – Northern Border Region – CFDA #93.912; Grant #1 U2SRH43523-01-00 – Year ended August 31, 2022) Criteria: According to 2 CFR section 200.305(b), non-federal entities must minimize the time elapsed between the transfer of federal funds and disbursement by the non-federal entity for direct program costs. Condition: Drawdown reports were not available for testing and financial reports weren’t available to determine that the time elapsed between the transfer of federal funds and disbursement by the non-federal entity for direct program costs was minimized. Effect: The entity may not be in compliance with the cash management requirements. Questioned Costs: $0 Context: There was a significant amount of turnover within the organization. Due to the turnover and the lack of record retention policies and procedures, records of drawdowns and documentation to support compliance with cash management requirements couldn’t be located. On November 14, 2022, the Company adopted new records management policies and procedures.
Rural Behavioral Health Workforce Coordinating Centers – Northern Border Region – CFDA #93.912; Grant #1 U2SRH43523-01-00 – Year ended August 31, 2022) Criteria: According to 2 CFR section 200.305(b), non-federal entities must minimize the time elapsed between the transfer of federal funds and disbursement by the non-federal entity for direct program costs. Condition: Drawdown reports were not available for testing and financial reports weren’t available to determine that the time elapsed between the transfer of federal funds and disbursement by the non-federal entity for direct program costs was minimized. Effect: The entity may not be in compliance with the cash management requirements. Questioned Costs: $0 Context: There was a significant amount of turnover within the organization. Due to the turnover and the lack of record retention policies and procedures, records of drawdowns and documentation to support compliance with cash management requirements couldn’t be located. On November 14, 2022, the Company adopted new records management policies and procedures.
Rural Behavioral Health Workforce Coordinating Centers – Northern Border Region – CFDA #93.912; Grant #1 U2SRH43523-01-00 – Year ended August 31, 2022) Criteria: According to 2 CFR section 200.305(b), non-federal entities must minimize the time elapsed between the transfer of federal funds and disbursement by the non-federal entity for direct program costs. Condition: Drawdown reports were not available for testing and financial reports weren’t available to determine that the time elapsed between the transfer of federal funds and disbursement by the non-federal entity for direct program costs was minimized. Effect: The entity may not be in compliance with the cash management requirements. Questioned Costs: $0 Context: There was a significant amount of turnover within the organization. Due to the turnover and the lack of record retention policies and procedures, records of drawdowns and documentation to support compliance with cash management requirements couldn’t be located. On November 14, 2022, the Company adopted new records management policies and procedures.
Rural Behavioral Health Workforce Coordinating Centers – Northern Border Region – CFDA #93.912; Grant #1 U2SRH43523-01-00 – Year ended August 31, 2022) Criteria: According to 2 CFR section 200.305(b), non-federal entities must minimize the time elapsed between the transfer of federal funds and disbursement by the non-federal entity for direct program costs. Condition: Drawdown reports were not available for testing and financial reports weren’t available to determine that the time elapsed between the transfer of federal funds and disbursement by the non-federal entity for direct program costs was minimized. Effect: The entity may not be in compliance with the cash management requirements. Questioned Costs: $0 Context: There was a significant amount of turnover within the organization. Due to the turnover and the lack of record retention policies and procedures, records of drawdowns and documentation to support compliance with cash management requirements couldn’t be located. On November 14, 2022, the Company adopted new records management policies and procedures.