Finding 2025.003 – Period of Performance – Significant Deficiency and Noncompliance Assistance Listing Number 14.267 - Continuum of Care, U.S. Department of Housing and Urban Services, Pass-Through Entity: State of Connecticut Department of Housing, Award Number: 24DOH0901CX, Pass-Through Entity: United Way of Southeastern Connecticut, Award Number: 21DOH1001DA Criteria A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award's period of performance that was authorized by the federal awarding agency or pass-through entity (2 CFR sections, 200.308, 200.309 and 200.403(h)). Condition Certain expenses were charged to the grant that were not properly obligated prior to the end of the grant period. Purchase orders were issued without placing the actual order, or the item was ordered after the period of performance concluded. Cause The Council did not have adequate policies, procedures and controls in place to ensure compliance with the requirements regarding period of performance. Effect or Potential Effect Inadequate controls over period of performance led to expenses charged to the grant that were not incurred during the required period of performance. Questioned Costs $2,113 Context We selected 5 expenditures for testing over the period of performance requirement. Out of the 5 expenditures tested, we noted 2 instances where expenditures were not spent or obligated appropriately in the right grant period. Identification as a Repeat Finding This is not a repeat finding. Recommendation We recommend that management implement additional controls and policies over period of performance. Staff who purchase items with grant funds should have additional training on period of performance requirements. Views of Responsible Officials TVCCA recognizes the validity of this finding. TVCCA is strengthening its period-of-performance controls by training all staff with purchasing authority, and finance staff, on grant deadlines, obligation definitions, and allowable spend-down periods. Internal controls will be enhanced by incorporating quarterly cutoff testing into the month-end close checklist. Additionally, cutoff testing results will be monitored quarterly as part of the quarter-end review process.
Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: 6/1/24-5/31/25 Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: A nonfederal entity may only charge allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency made the federal award that were authorized by the federal awarding agency (2 CFR sections 200.308, 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Cost incurred prior to the start of the period of performance were charged to the grant. Questioned Costs: $2,979 Context: Two of thirteen transactions selected for testing. Cause: These costs related to a payroll period which crossed over two different grant budget periods, and the costs allocated to the grant were not prorated for the number of days within the period of performance. Effect: Unallowable costs may be allocated to the grant. Repeat Finding: No. Recommendation: We recommend that only costs incurred during the period of performance be charged to the grant. For payroll in which pay periods extend over multiple budget periods, we recommend prorating the amount charged to the grant by the days worked within the grant period. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: 6/1/24-5/31/25 Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: A nonfederal entity may only charge allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency made the federal award that were authorized by the federal awarding agency (2 CFR sections 200.308, 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Cost incurred prior to the start of the period of performance were charged to the grant. Questioned Costs: $2,979 Context: Two of thirteen transactions selected for testing. Cause: These costs related to a payroll period which crossed over two different grant budget periods, and the costs allocated to the grant were not prorated for the number of days within the period of performance. Effect: Unallowable costs may be allocated to the grant. Repeat Finding: No. Recommendation: We recommend that only costs incurred during the period of performance be charged to the grant. For payroll in which pay periods extend over multiple budget periods, we recommend prorating the amount charged to the grant by the days worked within the grant period. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: 6/1/24-5/31/25 Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: A nonfederal entity may only charge allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency made the federal award that were authorized by the federal awarding agency (2 CFR sections 200.308, 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Cost incurred prior to the start of the period of performance were charged to the grant. Questioned Costs: $2,979 Context: Two of thirteen transactions selected for testing. Cause: These costs related to a payroll period which crossed over two different grant budget periods, and the costs allocated to the grant were not prorated for the number of days within the period of performance. Effect: Unallowable costs may be allocated to the grant. Repeat Finding: No. Recommendation: We recommend that only costs incurred during the period of performance be charged to the grant. For payroll in which pay periods extend over multiple budget periods, we recommend prorating the amount charged to the grant by the days worked within the grant period. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: 6/1/24-5/31/25 Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: A nonfederal entity may only charge allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency made the federal award that were authorized by the federal awarding agency (2 CFR sections 200.308, 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Cost incurred prior to the start of the period of performance were charged to the grant. Questioned Costs: $2,979 Context: Two of thirteen transactions selected for testing. Cause: These costs related to a payroll period which crossed over two different grant budget periods, and the costs allocated to the grant were not prorated for the number of days within the period of performance. Effect: Unallowable costs may be allocated to the grant. Repeat Finding: No. Recommendation: We recommend that only costs incurred during the period of performance be charged to the grant. For payroll in which pay periods extend over multiple budget periods, we recommend prorating the amount charged to the grant by the days worked within the grant period. Views of Responsible Officials: There is no disagreement with the audit finding.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 64.033, Department of Veteran Affairs, VA Supportive Services for Veteran Families Program Federal Award Identification Number and Year: 20-MI-221-SS, 20-MI-221-LT, 20-MI-221 Pass-through Entity – N/A Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 2 CFR § 200.403(h), cost must be incurred during the approved budget period. Budget period means the time interval from the start date of a funded portion of an award to the end date of that funded portion during which recipients are authorized to expend the funds awarded, including any funds carried forward or other revisions pursuant to 200.308. A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or passthrough entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Condition – During our testing for Period of Performance, it was noted that 1 out of 60 disbursements did not comply with the Period of Performance requirements as specified in the Supportive Services for Veteran Families grant agreement. Funds were disbursed for expenses incurred after the expiration date as noted in the grant agreement. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – Management did not follow their internal controls to ensure that compliance with Period of Performance requirements were met. Recommendation – We recommend that the Organization establish procedures and internal, controls to ensure that all expenditures charged under the grant fall within the required Period of Performance requirements as specified in the grant agreement. View of Responsible Officials and Corrective Action Plan – The Agency agrees with the finding. We will provide training to program managers who are approving program expenditures to ensure proper allocation of costs to the appropriate grant cycles. We will also update our purchasing procedures to ensure that the proper allocation of costs is reviewed prior to supervisor's approval of the cost.
2024-002: Significant Deficiency: Activities Allowed or Unallowable Costs/Cost Principles Criteria: In accordance with federal regulations, expenditures charged to federal awards must comply with the allowable cost principles outlined in 2 CFR Part 200, Subpart E. Furthermore, recipients and subrecipients are required to operate within the parameters of the approved budget as specified in the grant agreement. Any budgetary revisions must receive prior written approval from the awarding federal agency or pass-through entity, pursuant to 2 CFR § 200.308. Section III: Federal Award Findings and Questioned Costs (Continued) 2024-002: Significant Deficiency: Activities Allowed or Unallowable Costs/Cost Principles (Continued) Condition: During our audit procedures, we noted that the Organization incurred expenditures in excess of the approved amounts within certain budget categories. The reallocation of funds between these categories exceeded the allowable threshold of 10%, as stipulated in the grant agreement, without obtaining the required prior approval. Cause: The Organization’s internal controls over compliance related to the review and reconciliation of budgeted amounts against actual expenditures charged to the grant were not adequately designed or implemented to detect and prevent variances. Effect: As a result, costs submitted for reimbursement exceeded the approved budgetary limits for certain budget line items established in the grant agreement, rendering a portion of the expenditures unallowable under federal regulations. Questioned Costs: None Recommendation: We recommend that the Organization’s management evaluate and strengthen internal control over compliance procedures to ensure expenditures consistently comply with federal cost principles and remain within approved budget line items. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, 10.443 and 10.912 Name of Federal Program or Cluster: Research and Development Cluster Name of Federal Agency: Department of Agriculture Federal Award Identification Numbers: 58-5090-2-037 2022-38624-38368 2021-38640-34714 A0242501X443G026 2022-38640-37486 2023-51300-40959 2021-68012-35917 2019-68012-29852 2020-68012-31934 2021-49400-35592 NR225F48XXXXG006 Direct Award Periods: August 1, 2022 through July 31, 2027, September 1, 2023 through February 28, 2025, September 29, 2022 through September 30, 2027, September 27 2024 through September 26, 2027 and September 27, 2022 through June 30, 2026 Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through August 31, 2025; Regents of the University of Minnesota-March 1, 2022 through February 28, 2025, April 1, 2023 through March 31, 2025, and September 1, 2020 through August 31, 2025; Board of Regents of the University of Wisconsin System-January 1, 2022 through December 31, 2026 and September 1, 2018 through August 31, 2024. Criteria or Specific Requirement: In accordance with 2 CFR § 200.303, non-federal entities must establish and maintain effective internal control over federal awards to provide reasonable assurance that the entity is managing the award in compliance with federal statutes, regulations, and the terms and conditions of the award. Additionally, changes in key personnel typically require prior written approval from the federal awarding agency or pass-through entity, as described in 2 CFR § 200.308(c)(2). Condition: During the audit, we noted that the Organization does not have documented internal controls or formal procedures in place to monitor and manage compliance with the key personnel requirements under its federal awards. Specifically, There is no control in place to identify or track which personnel are designated as “key personnel” in award documents. No procedures exist to ensure that required prior approvals are obtained from the federal awarding agency before any changes in key personnel are made. No review or oversight process is in place to ensure that key personnel are actively participating at the level of effort committed in the approved award. Cause: The Organization has not developed or implemented policies and procedures to ensure compliance with special terms and conditions related to key personnel requirements under federal awards. Effect or Potential Effect: The lack of internal controls over key personnel requirements increases the risk that required prior approvals may not be obtained when changes occur, or that personnel effort commitments are not being met. This could result in noncompliance with the terms and conditions of the award, potential disallowance of costs, or reputational risk with federal awarding agencies. Repeat Finding: This finding is a repeat of Finding 2023-007. Recommendation: The Organization should implement internal controls and written procedures to: Identify and track key personnel for each award, based on the approved budget or notice of award. Establish a process to ensure that prior written approval is obtained before any changes to key personnel are made. Monitor and document key personnel effort to ensure it aligns with award requirements and commitments. Provide training to relevant staff on the importance of key personnel compliance and the procedures for requesting changes. Views of Responsible Officials: Management agrees with the finding and will implement internal controls and document its policies and procedures related to key personnel.
Finding Number: 2024-003 Federal Program: CDBG – Entitlement Grants Cluster Federal Award Identification Number and Year: B-22-MC-39-0001, 2024 Assistance Listing Number (ALN): 14.218 Federal Awarding Agency: Department of Housing and Urban Development Pass-through Entity: None Repeat Finding: No Material Weakness and Noncompliance – Period of Performance Criteria: A non-Federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity sections 2 CFR 200.308, 200.309, and 200.403(h). A period of performance may contain one or more budget periods. Condition: The City charged costs that were incurred prior to the beginning of the period of performance of the grant. Questioned Costs: Total of $44,198 Identification of How Questioned Costs Were Computed: Total known questioned costs of $22,110, and total projection of $22,088 for a total of $44,198. Context: During testing, we identified three operational journals with transactions that were incurred outside of the period of performance of the grant. The requirement is outlined in the funding approval/agreement and applicable guidelines referenced above. Cause and Effect: The City did not have internal controls in place to ensure that only costs that occurred within the period of performance were charged to grant. As a result, the City charged costs that were incurred prior to the start of the grant’s period of performance. Recommendation: The City should implement controls and processes to ensure costs are charged within the appropriate grant period. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
2024-010 Period of Performance Assistance Listing No.: 14.267 Continuum of Care Program Condition: The Organization was unable to demonstrate consistent controls over the period of performance requirement. Criteria: The requirements for the period of performance are contained in 2 CFR section 200.1 Definitions for “budget period,” “financial obligations,” “period of performance,” 2 CFR section 200.308 (revision of budget and program plans), 2 CFR section 200.309 (modifications to period of performance), 2 CFR section 200.344 (closeout), program legislation, federal awarding agency regulations; and the terms and conditions of the award. Questioned Costs There are no questioned costs. Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over. Effect: The Organization could have incurred grant expenditures outside the grant period. Perspective: Two of forty items selected for testing did not have documentation of the control over compliance with the period of performance requirement. Repeat Finding: This is a repeat finding. See finding 2023-014. Based on timing of prior year audit the Organization did not have time to fully correct the issue. Recommendation: In order to prevent future occurences of this deficiency, RBT recommends that management expand controls to ensure that they are able to demonstrate that all expenses meet their procurement policy. Auditee's Response: The Organization agrees with the finding. See attached corrective action plan.
2024 – 003 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2402LLIEA 6/1/2024; 2302ILLIEI 3/1/2023; G 2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038 Award Period: June 1, 2024 through September 30, 2025; March 1, 2023 through August 31, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.308, 200.309, and 200.403(h)) requires that only allowable costs incurred during the approved budget period of a federal award’s period of performance be charged to the award. Effective internal controls should include procedures that involve costs charged to federal awards being reviewed and approved for proper period of performance. Condition: The County charged costs to the federal award after the end of the period of performance. Furthermore, although payroll transactions charged to the federal award were reviewed and approved, documentation of such review was not retained. Questioned Costs: $706 Context: 4 of 97 transactions tested were incurred after the period of performance end date. All 18 payroll transactions tested lacked documentation of review and approval. Cause: Costs were inadvertently claimed outside the period of performance. Documentation of review and approval for payroll transactions was also not retained. Effect: Charging costs outside the period of performance can result in unallowable costs being charged to federal awards, which could lead to noncompliance with federal requirements and potential repayment obligations. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-005. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 003 Period of Performance (Continued) Recommendation: We recommend that the County review and strengthen its internal controls to ensure that only costs incurred within the period of performance are charged. Costs charged to federal awards should be reviewed and approved for proper period of performance, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 003 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2402LLIEA 6/1/2024; 2302ILLIEI 3/1/2023; G 2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038 Award Period: June 1, 2024 through September 30, 2025; March 1, 2023 through August 31, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.308, 200.309, and 200.403(h)) requires that only allowable costs incurred during the approved budget period of a federal award’s period of performance be charged to the award. Effective internal controls should include procedures that involve costs charged to federal awards being reviewed and approved for proper period of performance. Condition: The County charged costs to the federal award after the end of the period of performance. Furthermore, although payroll transactions charged to the federal award were reviewed and approved, documentation of such review was not retained. Questioned Costs: $706 Context: 4 of 97 transactions tested were incurred after the period of performance end date. All 18 payroll transactions tested lacked documentation of review and approval. Cause: Costs were inadvertently claimed outside the period of performance. Documentation of review and approval for payroll transactions was also not retained. Effect: Charging costs outside the period of performance can result in unallowable costs being charged to federal awards, which could lead to noncompliance with federal requirements and potential repayment obligations. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-005. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 003 Period of Performance (Continued) Recommendation: We recommend that the County review and strengthen its internal controls to ensure that only costs incurred within the period of performance are charged. Costs charged to federal awards should be reviewed and approved for proper period of performance, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 003 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2402LLIEA 6/1/2024; 2302ILLIEI 3/1/2023; G 2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038 Award Period: June 1, 2024 through September 30, 2025; March 1, 2023 through August 31, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.308, 200.309, and 200.403(h)) requires that only allowable costs incurred during the approved budget period of a federal award’s period of performance be charged to the award. Effective internal controls should include procedures that involve costs charged to federal awards being reviewed and approved for proper period of performance. Condition: The County charged costs to the federal award after the end of the period of performance. Furthermore, although payroll transactions charged to the federal award were reviewed and approved, documentation of such review was not retained. Questioned Costs: $706 Context: 4 of 97 transactions tested were incurred after the period of performance end date. All 18 payroll transactions tested lacked documentation of review and approval. Cause: Costs were inadvertently claimed outside the period of performance. Documentation of review and approval for payroll transactions was also not retained. Effect: Charging costs outside the period of performance can result in unallowable costs being charged to federal awards, which could lead to noncompliance with federal requirements and potential repayment obligations. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-005. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 003 Period of Performance (Continued) Recommendation: We recommend that the County review and strengthen its internal controls to ensure that only costs incurred within the period of performance are charged. Costs charged to federal awards should be reviewed and approved for proper period of performance, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 003 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2402LLIEA 6/1/2024; 2302ILLIEI 3/1/2023; G 2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038 Award Period: June 1, 2024 through September 30, 2025; March 1, 2023 through August 31, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.308, 200.309, and 200.403(h)) requires that only allowable costs incurred during the approved budget period of a federal award’s period of performance be charged to the award. Effective internal controls should include procedures that involve costs charged to federal awards being reviewed and approved for proper period of performance. Condition: The County charged costs to the federal award after the end of the period of performance. Furthermore, although payroll transactions charged to the federal award were reviewed and approved, documentation of such review was not retained. Questioned Costs: $706 Context: 4 of 97 transactions tested were incurred after the period of performance end date. All 18 payroll transactions tested lacked documentation of review and approval. Cause: Costs were inadvertently claimed outside the period of performance. Documentation of review and approval for payroll transactions was also not retained. Effect: Charging costs outside the period of performance can result in unallowable costs being charged to federal awards, which could lead to noncompliance with federal requirements and potential repayment obligations. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-005. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 003 Period of Performance (Continued) Recommendation: We recommend that the County review and strengthen its internal controls to ensure that only costs incurred within the period of performance are charged. Costs charged to federal awards should be reviewed and approved for proper period of performance, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 003 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2402LLIEA 6/1/2024; 2302ILLIEI 3/1/2023; G 2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038 Award Period: June 1, 2024 through September 30, 2025; March 1, 2023 through August 31, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.308, 200.309, and 200.403(h)) requires that only allowable costs incurred during the approved budget period of a federal award’s period of performance be charged to the award. Effective internal controls should include procedures that involve costs charged to federal awards being reviewed and approved for proper period of performance. Condition: The County charged costs to the federal award after the end of the period of performance. Furthermore, although payroll transactions charged to the federal award were reviewed and approved, documentation of such review was not retained. Questioned Costs: $706 Context: 4 of 97 transactions tested were incurred after the period of performance end date. All 18 payroll transactions tested lacked documentation of review and approval. Cause: Costs were inadvertently claimed outside the period of performance. Documentation of review and approval for payroll transactions was also not retained. Effect: Charging costs outside the period of performance can result in unallowable costs being charged to federal awards, which could lead to noncompliance with federal requirements and potential repayment obligations. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-005. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 003 Period of Performance (Continued) Recommendation: We recommend that the County review and strengthen its internal controls to ensure that only costs incurred within the period of performance are charged. Costs charged to federal awards should be reviewed and approved for proper period of performance, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 003 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2402LLIEA 6/1/2024; 2302ILLIEI 3/1/2023; G 2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038 Award Period: June 1, 2024 through September 30, 2025; March 1, 2023 through August 31, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.308, 200.309, and 200.403(h)) requires that only allowable costs incurred during the approved budget period of a federal award’s period of performance be charged to the award. Effective internal controls should include procedures that involve costs charged to federal awards being reviewed and approved for proper period of performance. Condition: The County charged costs to the federal award after the end of the period of performance. Furthermore, although payroll transactions charged to the federal award were reviewed and approved, documentation of such review was not retained. Questioned Costs: $706 Context: 4 of 97 transactions tested were incurred after the period of performance end date. All 18 payroll transactions tested lacked documentation of review and approval. Cause: Costs were inadvertently claimed outside the period of performance. Documentation of review and approval for payroll transactions was also not retained. Effect: Charging costs outside the period of performance can result in unallowable costs being charged to federal awards, which could lead to noncompliance with federal requirements and potential repayment obligations. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-005. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 003 Period of Performance (Continued) Recommendation: We recommend that the County review and strengthen its internal controls to ensure that only costs incurred within the period of performance are charged. Costs charged to federal awards should be reviewed and approved for proper period of performance, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 003 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2402LLIEA 6/1/2024; 2302ILLIEI 3/1/2023; G 2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038 Award Period: June 1, 2024 through September 30, 2025; March 1, 2023 through August 31, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.308, 200.309, and 200.403(h)) requires that only allowable costs incurred during the approved budget period of a federal award’s period of performance be charged to the award. Effective internal controls should include procedures that involve costs charged to federal awards being reviewed and approved for proper period of performance. Condition: The County charged costs to the federal award after the end of the period of performance. Furthermore, although payroll transactions charged to the federal award were reviewed and approved, documentation of such review was not retained. Questioned Costs: $706 Context: 4 of 97 transactions tested were incurred after the period of performance end date. All 18 payroll transactions tested lacked documentation of review and approval. Cause: Costs were inadvertently claimed outside the period of performance. Documentation of review and approval for payroll transactions was also not retained. Effect: Charging costs outside the period of performance can result in unallowable costs being charged to federal awards, which could lead to noncompliance with federal requirements and potential repayment obligations. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-005. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 003 Period of Performance (Continued) Recommendation: We recommend that the County review and strengthen its internal controls to ensure that only costs incurred within the period of performance are charged. Costs charged to federal awards should be reviewed and approved for proper period of performance, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 003 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2402LLIEA 6/1/2024; 2302ILLIEI 3/1/2023; G 2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038 Award Period: June 1, 2024 through September 30, 2025; March 1, 2023 through August 31, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.308, 200.309, and 200.403(h)) requires that only allowable costs incurred during the approved budget period of a federal award’s period of performance be charged to the award. Effective internal controls should include procedures that involve costs charged to federal awards being reviewed and approved for proper period of performance. Condition: The County charged costs to the federal award after the end of the period of performance. Furthermore, although payroll transactions charged to the federal award were reviewed and approved, documentation of such review was not retained. Questioned Costs: $706 Context: 4 of 97 transactions tested were incurred after the period of performance end date. All 18 payroll transactions tested lacked documentation of review and approval. Cause: Costs were inadvertently claimed outside the period of performance. Documentation of review and approval for payroll transactions was also not retained. Effect: Charging costs outside the period of performance can result in unallowable costs being charged to federal awards, which could lead to noncompliance with federal requirements and potential repayment obligations. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-005. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 003 Period of Performance (Continued) Recommendation: We recommend that the County review and strengthen its internal controls to ensure that only costs incurred within the period of performance are charged. Costs charged to federal awards should be reviewed and approved for proper period of performance, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 003 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2402LLIEA 6/1/2024; 2302ILLIEI 3/1/2023; G 2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038 Award Period: June 1, 2024 through September 30, 2025; March 1, 2023 through August 31, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.308, 200.309, and 200.403(h)) requires that only allowable costs incurred during the approved budget period of a federal award’s period of performance be charged to the award. Effective internal controls should include procedures that involve costs charged to federal awards being reviewed and approved for proper period of performance. Condition: The County charged costs to the federal award after the end of the period of performance. Furthermore, although payroll transactions charged to the federal award were reviewed and approved, documentation of such review was not retained. Questioned Costs: $706 Context: 4 of 97 transactions tested were incurred after the period of performance end date. All 18 payroll transactions tested lacked documentation of review and approval. Cause: Costs were inadvertently claimed outside the period of performance. Documentation of review and approval for payroll transactions was also not retained. Effect: Charging costs outside the period of performance can result in unallowable costs being charged to federal awards, which could lead to noncompliance with federal requirements and potential repayment obligations. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-005. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 003 Period of Performance (Continued) Recommendation: We recommend that the County review and strengthen its internal controls to ensure that only costs incurred within the period of performance are charged. Costs charged to federal awards should be reviewed and approved for proper period of performance, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 003 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2402LLIEA 6/1/2024; 2302ILLIEI 3/1/2023; G 2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038 Award Period: June 1, 2024 through September 30, 2025; March 1, 2023 through August 31, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.308, 200.309, and 200.403(h)) requires that only allowable costs incurred during the approved budget period of a federal award’s period of performance be charged to the award. Effective internal controls should include procedures that involve costs charged to federal awards being reviewed and approved for proper period of performance. Condition: The County charged costs to the federal award after the end of the period of performance. Furthermore, although payroll transactions charged to the federal award were reviewed and approved, documentation of such review was not retained. Questioned Costs: $706 Context: 4 of 97 transactions tested were incurred after the period of performance end date. All 18 payroll transactions tested lacked documentation of review and approval. Cause: Costs were inadvertently claimed outside the period of performance. Documentation of review and approval for payroll transactions was also not retained. Effect: Charging costs outside the period of performance can result in unallowable costs being charged to federal awards, which could lead to noncompliance with federal requirements and potential repayment obligations. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-005. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 003 Period of Performance (Continued) Recommendation: We recommend that the County review and strengthen its internal controls to ensure that only costs incurred within the period of performance are charged. Costs charged to federal awards should be reviewed and approved for proper period of performance, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-007 – Allowable Costs & Period of Performance (Material Weakness and Noncompliance) Information on the Federal Program: U.S. Department of Education, Higher Education- Institutional Aid (Title III), Assistance Listing No. 84.031 Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under federal awards. Non-federal entities are also required to establish controls over the disbursement process to ensure compliance with allowable cost requirements. In addition, a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition: We selected a sample of 25 non-payroll disbursements and 25 payroll disbursements charged to the grant. Of the 25 non-payroll, 4 were missing an approval by the Director of Title III Programs and 4 costs were not in the applicable budgets. In addition, 2 were charged to a fund code for a grant period that ended September 30, 2023. There were 44 pay checks tested in the sample of 25; of those 44, 31 exceptions were noted as having an issue around the approved pay rate documentation. In 9 instances, there was no documented approved pay rate, only support provided was a local salary schedule for multiple positions for 6 of the exceptions. In 15 instances, there was no approval for salary to be charged to the grant number and documentation showed unrestricted, a different account or offer letter had no Title III documentation. In 7 instances, the approved pay rate did not agree to actual paycheck report. Cause: The College did not obtain proper approval by the Director of the program, expenses did not fit into the grant budget line items, approved pay rates were not properly documented and the College continued to use funds after the grant period ended based on verbal instruction. Effect: The College’s grant disbursements were not properly approved. Questioned Costs: $35,461 Recommendation: We recommend the College strengthen its policies and procedures surrounding payroll and non-payroll grant disbursements to ensure controls are functioning and compliant with federal regulations Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
FINDING 2024-021 National Guard Military Operations and Maintenance (O&M) Projects, ALN 12.401, Period of Performance - Extension Procedures See Schedule of Findings and Questioned Costs for chart/table. Condition DMVA did not timely submit extension requests for cooperative agreement (CA) appendices sent to the USPFO for 2 (8%) of 24 appendices requiring extension requests during fiscal year 2024. For these 2 appendices, DMVA submitted the requests 111 days late. Criteria Federal regulation 2 CFR 200.303 requires the auditee to establish and maintain effective internal control over the federal awards that provides reasonable assurance the auditee is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Federal regulation 2 CFR 200.308 states a recipient must notify the federal agency in writing with the supporting justification and a revised period of performance at least 10 calendar days before the conclusions of the period of performance. The National Guard Bureau's Grants and Cooperative Agreement Policy Letter 21-07 indicates for projects and activities that cannot be completed before the end of a CA award's budget period of performance, the grantee must submit the extension request at least 10 days prior to the end of the period of performance. Cause DMVA's internal control and monitoring activities were not sufficient to ensure it timely submitted the required extension requests for CA appendices sent to the USPFO. Effect DMVA may have diminished the federal grantor agency's ability to ensure appropriate oversight and monitoring of the CA appendices. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend DMVA timely submit extension requests for CA appendices sent to the USPFO. Management Views DMVA agrees with the finding.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Research & Development Cluster Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria or Specific Requirement: The Organization should have processes and procedures in place to track key personnel compliance requirements, for the key personnel compliance requirement, per 2 CFR 200.308 (f) Condition: Auditor noted that 2 of the contracts had key personnel that was not being properly tracked. Cause: Internal control processes over tracking key personnel were not operating effectively. Effect: Errors noted with tracking key personnel. Questioned Costs: None Context: Out of the 17 samples that were tested, 2 of the samples were not in line with compliance requirements. The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding: N/A Recommendation: We recommend that procedures associated with tracking key personnel be strengthened. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.