Special Tests and Provisions – Key Personnel Research and Development Cluster, Assistance Listing Number: 84.031S Federal Granting Agency: U.S. Department of Education Program Year 2023–2024 Award No. PP031S220202-23 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Special Test - Key Personnel-Applications/proposals or awards may include staffing proposals that specify individuals who will work on the project and the extent of the planned involvement of personnel. The nonfederal entity may change the staffing mix and level of involvement within limits specified by agency policy or in the award, but may be required to obtain federal awarding agency approval of changes in key personnel (as identified in the award, which may differ from the nonfederal entity’s designation in the application/proposal) and changes in the project director’s time commitment/level of participation in the project (OMB Circular A-110 §§_.25(c)(2) and (3)/2 CFR Sections 200.308(b)(2) and (3)). Condition: Federal regulations provide that the University is responsible for ensuring the staffing mix and level of involvement is within limits specified by agency policy or in the award, and to obtain federal awarding agency approval of changes in key personnel. The University’s internal control system did not prevent or detect that key personnel did not complete personal activity reports to support their involvement in the project as required. Questioned Costs: None Context: Out of a population of 13 key personnel assigned to the grants, a sample of four key personnel were selected for testing. One out of the four key personnel did not have formal documentation related to charging their time to the project. Our sampling method was not, and was not intended to be, statistically valid. Effect: Management failed to perform effective control activities to appropriately reduce the risk of noncompliance related to the key personnel special test during the fiscal year. The lack of an adequate control environment over this special test requirement could result in personnel being involved in projects utilizing federal funds that have not been properly approved by the granting agency. Cause: The University’s processes did not ensure that key personnel were properly involved in projects under the Research and Development Cluster. Report Finding: No Recommendation: We recommend the University strengthen its processes and controls to help ensure that all key personnel involved in projects under the Research and Development Cluster are properly approved and involved in grant project objectives. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.
Special Tests and Provisions – Key Personnel Research and Development Cluster, Assistance Listing Number: 84.031S Federal Granting Agency: U.S. Department of Education Program Year 2023–2024 Award No. PP031S220202-23 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Special Test - Key Personnel-Applications/proposals or awards may include staffing proposals that specify individuals who will work on the project and the extent of the planned involvement of personnel. The nonfederal entity may change the staffing mix and level of involvement within limits specified by agency policy or in the award, but may be required to obtain federal awarding agency approval of changes in key personnel (as identified in the award, which may differ from the nonfederal entity’s designation in the application/proposal) and changes in the project director’s time commitment/level of participation in the project (OMB Circular A-110 §§_.25(c)(2) and (3)/2 CFR Sections 200.308(b)(2) and (3)). Condition: Federal regulations provide that the University is responsible for ensuring the staffing mix and level of involvement is within limits specified by agency policy or in the award, and to obtain federal awarding agency approval of changes in key personnel. The University’s internal control system did not prevent or detect that key personnel did not complete personal activity reports to support their involvement in the project as required. Questioned Costs: None Context: Out of a population of 13 key personnel assigned to the grants, a sample of four key personnel were selected for testing. One out of the four key personnel did not have formal documentation related to charging their time to the project. Our sampling method was not, and was not intended to be, statistically valid. Effect: Management failed to perform effective control activities to appropriately reduce the risk of noncompliance related to the key personnel special test during the fiscal year. The lack of an adequate control environment over this special test requirement could result in personnel being involved in projects utilizing federal funds that have not been properly approved by the granting agency. Cause: The University’s processes did not ensure that key personnel were properly involved in projects under the Research and Development Cluster. Report Finding: No Recommendation: We recommend the University strengthen its processes and controls to help ensure that all key personnel involved in projects under the Research and Development Cluster are properly approved and involved in grant project objectives. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.
Special Tests and Provisions – Key Personnel Research and Development Cluster, Assistance Listing Number: 84.031S Federal Granting Agency: U.S. Department of Education Program Year 2023–2024 Award No. PP031S220202-23 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Special Test - Key Personnel-Applications/proposals or awards may include staffing proposals that specify individuals who will work on the project and the extent of the planned involvement of personnel. The nonfederal entity may change the staffing mix and level of involvement within limits specified by agency policy or in the award, but may be required to obtain federal awarding agency approval of changes in key personnel (as identified in the award, which may differ from the nonfederal entity’s designation in the application/proposal) and changes in the project director’s time commitment/level of participation in the project (OMB Circular A-110 §§_.25(c)(2) and (3)/2 CFR Sections 200.308(b)(2) and (3)). Condition: Federal regulations provide that the University is responsible for ensuring the staffing mix and level of involvement is within limits specified by agency policy or in the award, and to obtain federal awarding agency approval of changes in key personnel. The University’s internal control system did not prevent or detect that key personnel did not complete personal activity reports to support their involvement in the project as required. Questioned Costs: None Context: Out of a population of 13 key personnel assigned to the grants, a sample of four key personnel were selected for testing. One out of the four key personnel did not have formal documentation related to charging their time to the project. Our sampling method was not, and was not intended to be, statistically valid. Effect: Management failed to perform effective control activities to appropriately reduce the risk of noncompliance related to the key personnel special test during the fiscal year. The lack of an adequate control environment over this special test requirement could result in personnel being involved in projects utilizing federal funds that have not been properly approved by the granting agency. Cause: The University’s processes did not ensure that key personnel were properly involved in projects under the Research and Development Cluster. Report Finding: No Recommendation: We recommend the University strengthen its processes and controls to help ensure that all key personnel involved in projects under the Research and Development Cluster are properly approved and involved in grant project objectives. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.
Special Tests and Provisions – Key Personnel Research and Development Cluster, Assistance Listing Number: 84.031S Federal Granting Agency: U.S. Department of Education Program Year 2023–2024 Award No. PP031S220202-23 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Special Test - Key Personnel-Applications/proposals or awards may include staffing proposals that specify individuals who will work on the project and the extent of the planned involvement of personnel. The nonfederal entity may change the staffing mix and level of involvement within limits specified by agency policy or in the award, but may be required to obtain federal awarding agency approval of changes in key personnel (as identified in the award, which may differ from the nonfederal entity’s designation in the application/proposal) and changes in the project director’s time commitment/level of participation in the project (OMB Circular A-110 §§_.25(c)(2) and (3)/2 CFR Sections 200.308(b)(2) and (3)). Condition: Federal regulations provide that the University is responsible for ensuring the staffing mix and level of involvement is within limits specified by agency policy or in the award, and to obtain federal awarding agency approval of changes in key personnel. The University’s internal control system did not prevent or detect that key personnel did not complete personal activity reports to support their involvement in the project as required. Questioned Costs: None Context: Out of a population of 13 key personnel assigned to the grants, a sample of four key personnel were selected for testing. One out of the four key personnel did not have formal documentation related to charging their time to the project. Our sampling method was not, and was not intended to be, statistically valid. Effect: Management failed to perform effective control activities to appropriately reduce the risk of noncompliance related to the key personnel special test during the fiscal year. The lack of an adequate control environment over this special test requirement could result in personnel being involved in projects utilizing federal funds that have not been properly approved by the granting agency. Cause: The University’s processes did not ensure that key personnel were properly involved in projects under the Research and Development Cluster. Report Finding: No Recommendation: We recommend the University strengthen its processes and controls to help ensure that all key personnel involved in projects under the Research and Development Cluster are properly approved and involved in grant project objectives. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.
Special Tests and Provisions – Key Personnel Research and Development Cluster, Assistance Listing Number: 84.031S Federal Granting Agency: U.S. Department of Education Program Year 2023–2024 Award No. PP031S220202-23 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Special Test - Key Personnel-Applications/proposals or awards may include staffing proposals that specify individuals who will work on the project and the extent of the planned involvement of personnel. The nonfederal entity may change the staffing mix and level of involvement within limits specified by agency policy or in the award, but may be required to obtain federal awarding agency approval of changes in key personnel (as identified in the award, which may differ from the nonfederal entity’s designation in the application/proposal) and changes in the project director’s time commitment/level of participation in the project (OMB Circular A-110 §§_.25(c)(2) and (3)/2 CFR Sections 200.308(b)(2) and (3)). Condition: Federal regulations provide that the University is responsible for ensuring the staffing mix and level of involvement is within limits specified by agency policy or in the award, and to obtain federal awarding agency approval of changes in key personnel. The University’s internal control system did not prevent or detect that key personnel did not complete personal activity reports to support their involvement in the project as required. Questioned Costs: None Context: Out of a population of 13 key personnel assigned to the grants, a sample of four key personnel were selected for testing. One out of the four key personnel did not have formal documentation related to charging their time to the project. Our sampling method was not, and was not intended to be, statistically valid. Effect: Management failed to perform effective control activities to appropriately reduce the risk of noncompliance related to the key personnel special test during the fiscal year. The lack of an adequate control environment over this special test requirement could result in personnel being involved in projects utilizing federal funds that have not been properly approved by the granting agency. Cause: The University’s processes did not ensure that key personnel were properly involved in projects under the Research and Development Cluster. Report Finding: No Recommendation: We recommend the University strengthen its processes and controls to help ensure that all key personnel involved in projects under the Research and Development Cluster are properly approved and involved in grant project objectives. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.
Special Tests and Provisions – Key Personnel Research and Development Cluster, Assistance Listing Number: 84.031S Federal Granting Agency: U.S. Department of Education Program Year 2023–2024 Award No. PP031S220202-23 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Special Test - Key Personnel-Applications/proposals or awards may include staffing proposals that specify individuals who will work on the project and the extent of the planned involvement of personnel. The nonfederal entity may change the staffing mix and level of involvement within limits specified by agency policy or in the award, but may be required to obtain federal awarding agency approval of changes in key personnel (as identified in the award, which may differ from the nonfederal entity’s designation in the application/proposal) and changes in the project director’s time commitment/level of participation in the project (OMB Circular A-110 §§_.25(c)(2) and (3)/2 CFR Sections 200.308(b)(2) and (3)). Condition: Federal regulations provide that the University is responsible for ensuring the staffing mix and level of involvement is within limits specified by agency policy or in the award, and to obtain federal awarding agency approval of changes in key personnel. The University’s internal control system did not prevent or detect that key personnel did not complete personal activity reports to support their involvement in the project as required. Questioned Costs: None Context: Out of a population of 13 key personnel assigned to the grants, a sample of four key personnel were selected for testing. One out of the four key personnel did not have formal documentation related to charging their time to the project. Our sampling method was not, and was not intended to be, statistically valid. Effect: Management failed to perform effective control activities to appropriately reduce the risk of noncompliance related to the key personnel special test during the fiscal year. The lack of an adequate control environment over this special test requirement could result in personnel being involved in projects utilizing federal funds that have not been properly approved by the granting agency. Cause: The University’s processes did not ensure that key personnel were properly involved in projects under the Research and Development Cluster. Report Finding: No Recommendation: We recommend the University strengthen its processes and controls to help ensure that all key personnel involved in projects under the Research and Development Cluster are properly approved and involved in grant project objectives. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.
2023-001- Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Information on the Major Federal Program U.S. Department of Health and Human Services Center for Disease Control and Prevention Assistance Listing Number: 93.988 Assistance Listing Name: Cooperative Agreements for State-Based Diabetes Control Programs and Evaluation of Surveillance Systems Grant Award Number(s): 1 NU58DP007372-01-00 Award Period: June 30, 2023 to June 29, 2028 Criteria or Specific Requirement – The Uniform Guidance 2 CFR Section 200.303 requires non-Federal entities receiving Federal awards establish and maintain internal control to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In addition, per 2 CFR Section 200.403, “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally- financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3).” Furthermore, according to the Uniform Guidance (2 CFR Part 200), specifically §200.430(i), “charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated”. The records must also be supported by the approval of an individual with firsthand knowledge of the work performed. Condition - During our audit, within the tested sample of seven timesheets out of a population of twenty-six, three timesheets for employees charged to the federal program did not have proper approval in the system. The lack of signed approval indicates that the timesheets were not reviewed and approved by an individual with knowledge of the work performed, as required under the Uniform Guidance. ADA has documented expenditure policies and procedures. However, the review and approval process did not operate as designed. Cause – ADA did not adhere to its internal policies and procedures to ensure timesheets were properly reviewed and approved. Effect or Potential Effect – Without adequate internal controls in place to ensure costs are properly verified and approved, ADA could unallowably and inaccurately charge salary and wages expenditures to the federal program. Questioned Costs – None Context - This is a condition based on testing of ADA’s compliance. Based on tested samples, we noted four out of seven sampled timesheets were not properly approved in the system. The samples were selected using a non-statistical method. Repeat Finding - This finding is not a repeat finding. Recommendation - BDO recommends that ADA adhere to its documented policies and procedures to ensure all timesheets are reviewed and approved by authorized personnel with knowledge of the work performed. ADA should also provide training to all employees involved in the timesheet preparation and approval process to ensure compliance with the Uniform Guidance requirements. Views of Responsible Officials: The findings were primarily related to a change that ADA made to the Human Resources Information System. Going forward, ADA will adhere to our documented policies and procedures to ensure all timesheets are reviewed and approved by authorized personnel with knowledge of the work performed. Additionally, we will provide training to all employees involved in the timesheet preparation and approval process to ensure compliance with the Uniform Guidance requirements.
Federal agency: All agencies in the SEFA Assistance Listing Number: See SEFA Award Period: 01/01/2023 to 12/31/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The compliance requirements for Federal Assistance Number 93.558 – Temporary Assistance for Needy Families (TANF) State Programs includes a Period of Performance element. The compliance requirement related to period of performance is that a non-federal entity may charge only allowable costs incurred during the approved budget period (also identified as the grant 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: Allocations of indirect costs are performed once during the year-end closing process based on time study data for the entire year, and when program attendance data for programs that are ran for various increments throughout the year is available. The TANF grant period that was tested as a major program was December 2022 – August 2023. As the grant period ended in September, no costs incurred after that date should be considered major program expenditures. Questioned Costs: Indeterminable. The questioned costs could be considered those indirect costs considered TANF expenditures that were incurred after August 2023. In addition, because the program attendance is used to allocate costs between programs, program attendance after August 2023 may be inappropriate to be considered when allocating those indirect costs to specific programs. Context: Indirect cost allocations are performed once during the year-end closing process by the auditee. Time studies are performed to allocate indirect costs between supporting and program functions. The indirect costs allocated to the program functions are then allocated between individual programs, including federally funded programs, based on the number of participant hours in each program. The time study and program hours used to allocate indirect costs are based on the entire year and not just the major program grant period. In addition, indirect costs that are allocated are incurred during the entire year and not just the major program grant period. Cause: Time and program participation data used to allocate costs are not consistent with the grant period. In addition, the costs that are allocated are not consistent with the grant period. Effect: The single annual allocation of costs means that costs incurred outside the major program grant/budget period are being allocated to the major program. In addition, allocation base data from outside the grant/budget period is being used as a base for the indirect cost allocation. Repeat Finding: No Auditor’s Recommendation: We recommend the auditee perform indirect cost allocations so that the costs and allocation base align with the grant/budget period. Performing the allocation of indirect costs annually may not create an equitable allocation at the individual program level. Views of Responsible Officials and Planned Corrective Actions: We agree that the allocation being performed once annually does not create the most equitable allocation of costs between our individual programs. We will perform our indirect cost allocations more periodically during the course of the fiscal year to ensure that more appropriate times studies and applicable participant hours are being utilized to limit the potential of allocating unrelated indirect costs from the year to individual programs, including the federally funded programs.
Federal agency: All agencies in the SEFA Assistance Listing Number: See SEFA Award Period: 01/01/2023 to 12/31/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The compliance requirements for Federal Assistance Number 93.558 – Temporary Assistance for Needy Families (TANF) State Programs includes a Period of Performance element. The compliance requirement related to period of performance is that a non-federal entity may charge only allowable costs incurred during the approved budget period (also identified as the grant 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: Allocations of indirect costs are performed once during the year-end closing process based on time study data for the entire year, and when program attendance data for programs that are ran for various increments throughout the year is available. The TANF grant period that was tested as a major program was December 2022 – August 2023. As the grant period ended in September, no costs incurred after that date should be considered major program expenditures. Questioned Costs: Indeterminable. The questioned costs could be considered those indirect costs considered TANF expenditures that were incurred after August 2023. In addition, because the program attendance is used to allocate costs between programs, program attendance after August 2023 may be inappropriate to be considered when allocating those indirect costs to specific programs. Context: Indirect cost allocations are performed once during the year-end closing process by the auditee. Time studies are performed to allocate indirect costs between supporting and program functions. The indirect costs allocated to the program functions are then allocated between individual programs, including federally funded programs, based on the number of participant hours in each program. The time study and program hours used to allocate indirect costs are based on the entire year and not just the major program grant period. In addition, indirect costs that are allocated are incurred during the entire year and not just the major program grant period. Cause: Time and program participation data used to allocate costs are not consistent with the grant period. In addition, the costs that are allocated are not consistent with the grant period. Effect: The single annual allocation of costs means that costs incurred outside the major program grant/budget period are being allocated to the major program. In addition, allocation base data from outside the grant/budget period is being used as a base for the indirect cost allocation. Repeat Finding: No Auditor’s Recommendation: We recommend the auditee perform indirect cost allocations so that the costs and allocation base align with the grant/budget period. Performing the allocation of indirect costs annually may not create an equitable allocation at the individual program level. Views of Responsible Officials and Planned Corrective Actions: We agree that the allocation being performed once annually does not create the most equitable allocation of costs between our individual programs. We will perform our indirect cost allocations more periodically during the course of the fiscal year to ensure that more appropriate times studies and applicable participant hours are being utilized to limit the potential of allocating unrelated indirect costs from the year to individual programs, including the federally funded programs.
Federal Program Information: Funding Agency: U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: H49MC00119‐19‐00 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2018‐2020 Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR sections 200.308 200.309 and 200.403(h)), the Organization 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. Condition: The Organization lacked supporting documentation for non‐payroll expenses. Due to lack of supporting documentation, period of performance could not be verified. Of the sixty (60) nonpayroll transactions examined, ten (10) lacked supporting documentation for review, and 1 expense was for services performed in a prior period. Effect: Management possibly did not expend funds in accordance with the approved detailed lineitem budget and grant agreement and possibly expended funds in the incorrect period of performance. Cause: Expenses including approved invoices and/or supporting documentation were not properly maintained in part due to several changes in personnel within the accounting area and overall limited number of personnel for certain functions and lack of board oversight. Questioned costs: Known questioned costs of $7,674 and likely questioned costs of $34,117 for Healthy Start. Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all expenses include supporting documentation/invoice indicating period of performance.
Federal Program Information: Funding Agency: U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: H49MC00119‐19‐00 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2018‐2020 Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR sections 200.308 200.309 and 200.403(h)), the Organization 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. Condition: The Organization lacked supporting documentation for non‐payroll expenses. Due to lack of supporting documentation, period of performance could not be verified. Of the sixty (60) nonpayroll transactions examined, ten (10) lacked supporting documentation for review, and 1 expense was for services performed in a prior period. Effect: Management possibly did not expend funds in accordance with the approved detailed lineitem budget and grant agreement and possibly expended funds in the incorrect period of performance. Cause: Expenses including approved invoices and/or supporting documentation were not properly maintained in part due to several changes in personnel within the accounting area and overall limited number of personnel for certain functions and lack of board oversight. Questioned costs: Known questioned costs of $7,674 and likely questioned costs of $34,117 for Healthy Start. Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all expenses include supporting documentation/invoice indicating period of performance.
Federal Agency: Department of Justice Federal Assistance Listing Number: 16.756 Program: Court Appointed Special Advocates Award Number: 15JDP-21-GK-02762-CASA Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation. “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: a) Be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b). g) Be adequately documented. See also §200.300 through §200.309. h) Cost must be incurred during the approved budget period. The federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).” Condition: National CASA/GAL allocated expenditures to programs during 2023 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries), we noted in accordance with §200.403(g) that: • 4 of 60 transactions was partially charged in the incorrect fiscal period, though within the period of performance. The cost of these 4 transactions were $5,246. • 2 of 60 transactions had an error in the allocation rate utilized. The cost of these 8 transactions were $33. • 4 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs. Known Questioned Costs: $5,279 Likely Questioned Costs: $131,271 Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs in 2023 were $3,612,154. The sample tested consisted of 60 transactions totaling $145,247. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. Identification as a Repeat Finding: 2022-004 and 2022-008. Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations, is appropriately maintained as required by §200.403. Views of Responsible Officials: Management concurs with the finding that documentation of support and allocation of costs should be maintained. Policies and procedures were enhanced in 2023 and through 2024 to ensure compliance.
FINDING 2023-002 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Period of Performance Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): CY 2023 Compliance Requirement: Period of Performance Audit Findings: Material Weakness, Modified Opinion Condition and Context On December 15, 2020, the City entered into a Lease-Purchase agreement with the Crossroads Bank for police and fire radios. On August 28, 2023, the City made a payment of $2,431,243 to the Crossroads Bank to pay the remaining balance due for the police and fire radios from its Coronavirus State and Local Fiscal Recovery Funds (SLFRF) allocation. Per SLFRF program regulations, the period of performance for the SLFRF award began on March 3, 2021, when the funds were disbursed by the grantor agency. All costs must be incurred by December 31, 2024, and funds must be liquidated before December 31, 2026. Although the City's purchase is an eligible purchase under the SLFRF Final Rule, the purchase was initiated and approved by the City prior to the SLFRF period of performance beginning date of March 3, 2021. Further, the project was not prospective in nature, and the City incurred a financial obligation prior to the beginning of the period of performance. As such, the payment of $2,431,243 was determined to be questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 31 CFR 35.5(a) states: "In general. A recipient may only use funds for the purposes enumerated in § 35.6 (b) through (f) to cover costs incurred during the period beginning March 3, 2021, and ending December 31, 2024, subject to the restrictions set forth in sections 602(c)(2) and 603(c)(2) of the Social Security Act, as applicable. A recipient may only use funds for the purposes enumerated in § 35.6 (g) through (h) to cover costs incurred during the period beginning December 29, 2022, and ending December 31, 2024, subject to the restrictions set forth in sections 602(c)(2), 602(c)(5)(C), 603(c)(2), and 603(c)(6)(B) of the Social Security Act, as applicable." 31 CFR 35.3 states in part: ". . . Obligation means an order placed for property and services and entering into contracts, subawards, and similar transactions that require payment. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3)." Cause Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the City's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these polices. The system of internal controls, as designed and implemented by management of the City, was not effective to ensure SLFRF funds were used appropriately. The original date of the contract was not considered when determining the funding source of the payment. Effect Without the proper implementation of an effectively designed system of internal controls, a payment on a debt associated with a project outside of the period of performance occurred. Noncompliance with the provisions of federal statutes, regulations, and terms and conditions of the federal award could result in the loss of future federal funding to the City. Questioned Costs Known questioned costs in the amount of $2,431,243 were identified as noted in the Condition and Context. Recommendation We recommended that management of the City establish a system of internal controls and develop policies and procedures to ensure SLFRF funds are used appropriately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2023-002 Significant deficiency in internal controls over compliance related to period of performance. Federal Agency: Department of Health and Human Services Program Title: Unaccompanied Alien Children Program Assistance Listing Number: 93.676 Award Numbers: 90ZU0339/03 and 90ZU0587/01 Project Period: February 1, 2022 - October 31, 2023 and November 1, 2023 - October 31, 2024 Criteria A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. Any costs incurred before the federal awarding agency or pass-through entity made the federal award, must be authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). Condition/Context for Evaluation During the audit for the year ending December 31, 2023, we noted four instances out of 40 where the Organization charged costs to the grant that were outside of the period of performance for the related award. Questioned Costs 90ZU0339/03 - $995 90ZU0587/01 - $408 Cause The Organization’s internal controls were not sufficient to ensure proper cutoff of grant expenditures and the allocation to the related award. Effect or Potential Effect Unallowable costs were charged to the grant. Repeat Finding Not Applicable. Recommendation We recommend that management develop internal controls for appropriate cutoff of grant expenditures and review to ensure the appropriate costs were charged to the budgeted period to the grant. Views of Responsible Officials of Auditee Management concurs with the finding and has provided the accompanying management corrective action.
Finding 2023-002 Significant deficiency in internal controls over compliance related to period of performance. Federal Agency: Department of Health and Human Services Program Title: Unaccompanied Alien Children Program Assistance Listing Number: 93.676 Award Numbers: 90ZU0339/03 and 90ZU0587/01 Project Period: February 1, 2022 - October 31, 2023 and November 1, 2023 - October 31, 2024 Criteria A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. Any costs incurred before the federal awarding agency or pass-through entity made the federal award, must be authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). Condition/Context for Evaluation During the audit for the year ending December 31, 2023, we noted four instances out of 40 where the Organization charged costs to the grant that were outside of the period of performance for the related award. Questioned Costs 90ZU0339/03 - $995 90ZU0587/01 - $408 Cause The Organization’s internal controls were not sufficient to ensure proper cutoff of grant expenditures and the allocation to the related award. Effect or Potential Effect Unallowable costs were charged to the grant. Repeat Finding Not Applicable. Recommendation We recommend that management develop internal controls for appropriate cutoff of grant expenditures and review to ensure the appropriate costs were charged to the budgeted period to the grant. Views of Responsible Officials of Auditee Management concurs with the finding and has provided the accompanying management corrective action.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.303(a) which requires that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.403 which states except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also § 200.306(b). (g) Be adequately documented. See also §§ 200.300 through 200.309 of this part. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3). State ex rel. McClure v. Hagerman, 155 Ohio St. 320 (1951) provides that expenditures made by a governmental unit should serve a public purpose. Typically, the determination of what constitutes a “proper public purpose” rests with the judgment of the governmental entity, unless such determination is arbitrary or unreasonable. Even if a purchase is reasonable, Ohio Attorney General Opinion 82-006 indicates that it must be memorialized by a duly enacted ordinance or resolution and may have a prospective effect only. Auditor of State Bulletin 2003-005 Expenditure of Public Funds/Proper “Public Purpose” states, in part, the Auditor of State’s Office will only question expenditures where the legislative determination of a public purpose is manifestly arbitrary and incorrect. The Lima-Allen County Regional Planning Commission, administrator of the Community Housing Impact and Preservation Program - CHIP (#B-C-21-1AB-1) for Allen County, incurred a charge of $4,386 for Admin January 2023 charges on invoice #106558 dated February 7, 2023 from the Great Lakes Community Action Partnership. On July 6, 2023, check number 7330652 was issued by Allen County which included payment of $4,386 on invoice number 106558. On August 3, 2023, check number 7332670 was issued by Allen County which included payment of $4,386 on invoice number 106558 which was approved by Tara Bales, Executive Director of the Lima-Allen County Regional Planning Commission. As a result, possibly due to the failure of an existing control or procedure, invoice number 106558 was paid twice resulting an overpayment of $4,386. On October 2, 2024, the Great Lakes Community Action Partnership refunded the overpayment with check number 20765 in the amount of $4,386. This refund was recorded in the Community Development Grant Fund (2414). The Lima-Allen County Regional Planning Commission should implement an additional control(s) and/or procedure(s) to prevent the duplicate payment of invoices.
2023-014 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 grant expenditures outside the grant period. Perspective: Thirty-one 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 2022-017. Recommendation: In order to prevent future occurences of this deficiency, we recommend 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.
2023-014 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 grant expenditures outside the grant period. Perspective: Thirty-one 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 2022-017. Recommendation: In order to prevent future occurences of this deficiency, we recommend 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.
2023-014 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 grant expenditures outside the grant period. Perspective: Thirty-one 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 2022-017. Recommendation: In order to prevent future occurences of this deficiency, we recommend 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.
2023-001- Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Information on the Major Federal Program U.S. Department of Health and Human Services Center for Disease Control and Prevention Assistance Listing Number: 93.988 Assistance Listing Name: Cooperative Agreements for State-Based Diabetes Control Programs and Evaluation of Surveillance Systems Grant Award Number(s): 1 NU58DP007372-01-00 Award Period: June 30, 2023 to June 29, 2028 Criteria or Specific Requirement – The Uniform Guidance 2 CFR Section 200.303 requires non-Federal entities receiving Federal awards establish and maintain internal control to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In addition, per 2 CFR Section 200.403, “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally- financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3).” Furthermore, according to the Uniform Guidance (2 CFR Part 200), specifically §200.430(i), “charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated”. The records must also be supported by the approval of an individual with firsthand knowledge of the work performed. Condition - During our audit, within the tested sample of seven timesheets out of a population of twenty-six, three timesheets for employees charged to the federal program did not have proper approval in the system. The lack of signed approval indicates that the timesheets were not reviewed and approved by an individual with knowledge of the work performed, as required under the Uniform Guidance. ADA has documented expenditure policies and procedures. However, the review and approval process did not operate as designed. Cause – ADA did not adhere to its internal policies and procedures to ensure timesheets were properly reviewed and approved. Effect or Potential Effect – Without adequate internal controls in place to ensure costs are properly verified and approved, ADA could unallowably and inaccurately charge salary and wages expenditures to the federal program. Questioned Costs – None Context - This is a condition based on testing of ADA’s compliance. Based on tested samples, we noted four out of seven sampled timesheets were not properly approved in the system. The samples were selected using a non-statistical method. Repeat Finding - This finding is not a repeat finding. Recommendation - BDO recommends that ADA adhere to its documented policies and procedures to ensure all timesheets are reviewed and approved by authorized personnel with knowledge of the work performed. ADA should also provide training to all employees involved in the timesheet preparation and approval process to ensure compliance with the Uniform Guidance requirements. Views of Responsible Officials: The findings were primarily related to a change that ADA made to the Human Resources Information System. Going forward, ADA will adhere to our documented policies and procedures to ensure all timesheets are reviewed and approved by authorized personnel with knowledge of the work performed. Additionally, we will provide training to all employees involved in the timesheet preparation and approval process to ensure compliance with the Uniform Guidance requirements.
Federal agency: All agencies in the SEFA Assistance Listing Number: See SEFA Award Period: 01/01/2023 to 12/31/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The compliance requirements for Federal Assistance Number 93.558 – Temporary Assistance for Needy Families (TANF) State Programs includes a Period of Performance element. The compliance requirement related to period of performance is that a non-federal entity may charge only allowable costs incurred during the approved budget period (also identified as the grant 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: Allocations of indirect costs are performed once during the year-end closing process based on time study data for the entire year, and when program attendance data for programs that are ran for various increments throughout the year is available. The TANF grant period that was tested as a major program was December 2022 – August 2023. As the grant period ended in September, no costs incurred after that date should be considered major program expenditures. Questioned Costs: Indeterminable. The questioned costs could be considered those indirect costs considered TANF expenditures that were incurred after August 2023. In addition, because the program attendance is used to allocate costs between programs, program attendance after August 2023 may be inappropriate to be considered when allocating those indirect costs to specific programs. Context: Indirect cost allocations are performed once during the year-end closing process by the auditee. Time studies are performed to allocate indirect costs between supporting and program functions. The indirect costs allocated to the program functions are then allocated between individual programs, including federally funded programs, based on the number of participant hours in each program. The time study and program hours used to allocate indirect costs are based on the entire year and not just the major program grant period. In addition, indirect costs that are allocated are incurred during the entire year and not just the major program grant period. Cause: Time and program participation data used to allocate costs are not consistent with the grant period. In addition, the costs that are allocated are not consistent with the grant period. Effect: The single annual allocation of costs means that costs incurred outside the major program grant/budget period are being allocated to the major program. In addition, allocation base data from outside the grant/budget period is being used as a base for the indirect cost allocation. Repeat Finding: No Auditor’s Recommendation: We recommend the auditee perform indirect cost allocations so that the costs and allocation base align with the grant/budget period. Performing the allocation of indirect costs annually may not create an equitable allocation at the individual program level. Views of Responsible Officials and Planned Corrective Actions: We agree that the allocation being performed once annually does not create the most equitable allocation of costs between our individual programs. We will perform our indirect cost allocations more periodically during the course of the fiscal year to ensure that more appropriate times studies and applicable participant hours are being utilized to limit the potential of allocating unrelated indirect costs from the year to individual programs, including the federally funded programs.
Federal agency: All agencies in the SEFA Assistance Listing Number: See SEFA Award Period: 01/01/2023 to 12/31/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The compliance requirements for Federal Assistance Number 93.558 – Temporary Assistance for Needy Families (TANF) State Programs includes a Period of Performance element. The compliance requirement related to period of performance is that a non-federal entity may charge only allowable costs incurred during the approved budget period (also identified as the grant 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: Allocations of indirect costs are performed once during the year-end closing process based on time study data for the entire year, and when program attendance data for programs that are ran for various increments throughout the year is available. The TANF grant period that was tested as a major program was December 2022 – August 2023. As the grant period ended in September, no costs incurred after that date should be considered major program expenditures. Questioned Costs: Indeterminable. The questioned costs could be considered those indirect costs considered TANF expenditures that were incurred after August 2023. In addition, because the program attendance is used to allocate costs between programs, program attendance after August 2023 may be inappropriate to be considered when allocating those indirect costs to specific programs. Context: Indirect cost allocations are performed once during the year-end closing process by the auditee. Time studies are performed to allocate indirect costs between supporting and program functions. The indirect costs allocated to the program functions are then allocated between individual programs, including federally funded programs, based on the number of participant hours in each program. The time study and program hours used to allocate indirect costs are based on the entire year and not just the major program grant period. In addition, indirect costs that are allocated are incurred during the entire year and not just the major program grant period. Cause: Time and program participation data used to allocate costs are not consistent with the grant period. In addition, the costs that are allocated are not consistent with the grant period. Effect: The single annual allocation of costs means that costs incurred outside the major program grant/budget period are being allocated to the major program. In addition, allocation base data from outside the grant/budget period is being used as a base for the indirect cost allocation. Repeat Finding: No Auditor’s Recommendation: We recommend the auditee perform indirect cost allocations so that the costs and allocation base align with the grant/budget period. Performing the allocation of indirect costs annually may not create an equitable allocation at the individual program level. Views of Responsible Officials and Planned Corrective Actions: We agree that the allocation being performed once annually does not create the most equitable allocation of costs between our individual programs. We will perform our indirect cost allocations more periodically during the course of the fiscal year to ensure that more appropriate times studies and applicable participant hours are being utilized to limit the potential of allocating unrelated indirect costs from the year to individual programs, including the federally funded programs.
Federal Program Information: Funding Agency: U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: H49MC00119‐19‐00 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2018‐2020 Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR sections 200.308 200.309 and 200.403(h)), the Organization 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. Condition: The Organization lacked supporting documentation for non‐payroll expenses. Due to lack of supporting documentation, period of performance could not be verified. Of the sixty (60) nonpayroll transactions examined, ten (10) lacked supporting documentation for review, and 1 expense was for services performed in a prior period. Effect: Management possibly did not expend funds in accordance with the approved detailed lineitem budget and grant agreement and possibly expended funds in the incorrect period of performance. Cause: Expenses including approved invoices and/or supporting documentation were not properly maintained in part due to several changes in personnel within the accounting area and overall limited number of personnel for certain functions and lack of board oversight. Questioned costs: Known questioned costs of $7,674 and likely questioned costs of $34,117 for Healthy Start. Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all expenses include supporting documentation/invoice indicating period of performance.
Federal Program Information: Funding Agency: U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: H49MC00119‐19‐00 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2018‐2020 Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR sections 200.308 200.309 and 200.403(h)), the Organization 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. Condition: The Organization lacked supporting documentation for non‐payroll expenses. Due to lack of supporting documentation, period of performance could not be verified. Of the sixty (60) nonpayroll transactions examined, ten (10) lacked supporting documentation for review, and 1 expense was for services performed in a prior period. Effect: Management possibly did not expend funds in accordance with the approved detailed lineitem budget and grant agreement and possibly expended funds in the incorrect period of performance. Cause: Expenses including approved invoices and/or supporting documentation were not properly maintained in part due to several changes in personnel within the accounting area and overall limited number of personnel for certain functions and lack of board oversight. Questioned costs: Known questioned costs of $7,674 and likely questioned costs of $34,117 for Healthy Start. Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all expenses include supporting documentation/invoice indicating period of performance.
Federal Agency: Department of Justice Federal Assistance Listing Number: 16.756 Program: Court Appointed Special Advocates Award Number: 15JDP-21-GK-02762-CASA Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation. “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: a) Be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b). g) Be adequately documented. See also §200.300 through §200.309. h) Cost must be incurred during the approved budget period. The federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).” Condition: National CASA/GAL allocated expenditures to programs during 2023 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries), we noted in accordance with §200.403(g) that: • 4 of 60 transactions was partially charged in the incorrect fiscal period, though within the period of performance. The cost of these 4 transactions were $5,246. • 2 of 60 transactions had an error in the allocation rate utilized. The cost of these 8 transactions were $33. • 4 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs. Known Questioned Costs: $5,279 Likely Questioned Costs: $131,271 Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs in 2023 were $3,612,154. The sample tested consisted of 60 transactions totaling $145,247. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. Identification as a Repeat Finding: 2022-004 and 2022-008. Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations, is appropriately maintained as required by §200.403. Views of Responsible Officials: Management concurs with the finding that documentation of support and allocation of costs should be maintained. Policies and procedures were enhanced in 2023 and through 2024 to ensure compliance.
FINDING 2023-002 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Period of Performance Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): CY 2023 Compliance Requirement: Period of Performance Audit Findings: Material Weakness, Modified Opinion Condition and Context On December 15, 2020, the City entered into a Lease-Purchase agreement with the Crossroads Bank for police and fire radios. On August 28, 2023, the City made a payment of $2,431,243 to the Crossroads Bank to pay the remaining balance due for the police and fire radios from its Coronavirus State and Local Fiscal Recovery Funds (SLFRF) allocation. Per SLFRF program regulations, the period of performance for the SLFRF award began on March 3, 2021, when the funds were disbursed by the grantor agency. All costs must be incurred by December 31, 2024, and funds must be liquidated before December 31, 2026. Although the City's purchase is an eligible purchase under the SLFRF Final Rule, the purchase was initiated and approved by the City prior to the SLFRF period of performance beginning date of March 3, 2021. Further, the project was not prospective in nature, and the City incurred a financial obligation prior to the beginning of the period of performance. As such, the payment of $2,431,243 was determined to be questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 31 CFR 35.5(a) states: "In general. A recipient may only use funds for the purposes enumerated in § 35.6 (b) through (f) to cover costs incurred during the period beginning March 3, 2021, and ending December 31, 2024, subject to the restrictions set forth in sections 602(c)(2) and 603(c)(2) of the Social Security Act, as applicable. A recipient may only use funds for the purposes enumerated in § 35.6 (g) through (h) to cover costs incurred during the period beginning December 29, 2022, and ending December 31, 2024, subject to the restrictions set forth in sections 602(c)(2), 602(c)(5)(C), 603(c)(2), and 603(c)(6)(B) of the Social Security Act, as applicable." 31 CFR 35.3 states in part: ". . . Obligation means an order placed for property and services and entering into contracts, subawards, and similar transactions that require payment. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3)." Cause Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the City's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these polices. The system of internal controls, as designed and implemented by management of the City, was not effective to ensure SLFRF funds were used appropriately. The original date of the contract was not considered when determining the funding source of the payment. Effect Without the proper implementation of an effectively designed system of internal controls, a payment on a debt associated with a project outside of the period of performance occurred. Noncompliance with the provisions of federal statutes, regulations, and terms and conditions of the federal award could result in the loss of future federal funding to the City. Questioned Costs Known questioned costs in the amount of $2,431,243 were identified as noted in the Condition and Context. Recommendation We recommended that management of the City establish a system of internal controls and develop policies and procedures to ensure SLFRF funds are used appropriately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2023-002 Significant deficiency in internal controls over compliance related to period of performance. Federal Agency: Department of Health and Human Services Program Title: Unaccompanied Alien Children Program Assistance Listing Number: 93.676 Award Numbers: 90ZU0339/03 and 90ZU0587/01 Project Period: February 1, 2022 - October 31, 2023 and November 1, 2023 - October 31, 2024 Criteria A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. Any costs incurred before the federal awarding agency or pass-through entity made the federal award, must be authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). Condition/Context for Evaluation During the audit for the year ending December 31, 2023, we noted four instances out of 40 where the Organization charged costs to the grant that were outside of the period of performance for the related award. Questioned Costs 90ZU0339/03 - $995 90ZU0587/01 - $408 Cause The Organization’s internal controls were not sufficient to ensure proper cutoff of grant expenditures and the allocation to the related award. Effect or Potential Effect Unallowable costs were charged to the grant. Repeat Finding Not Applicable. Recommendation We recommend that management develop internal controls for appropriate cutoff of grant expenditures and review to ensure the appropriate costs were charged to the budgeted period to the grant. Views of Responsible Officials of Auditee Management concurs with the finding and has provided the accompanying management corrective action.
Finding 2023-002 Significant deficiency in internal controls over compliance related to period of performance. Federal Agency: Department of Health and Human Services Program Title: Unaccompanied Alien Children Program Assistance Listing Number: 93.676 Award Numbers: 90ZU0339/03 and 90ZU0587/01 Project Period: February 1, 2022 - October 31, 2023 and November 1, 2023 - October 31, 2024 Criteria A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. Any costs incurred before the federal awarding agency or pass-through entity made the federal award, must be authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). Condition/Context for Evaluation During the audit for the year ending December 31, 2023, we noted four instances out of 40 where the Organization charged costs to the grant that were outside of the period of performance for the related award. Questioned Costs 90ZU0339/03 - $995 90ZU0587/01 - $408 Cause The Organization’s internal controls were not sufficient to ensure proper cutoff of grant expenditures and the allocation to the related award. Effect or Potential Effect Unallowable costs were charged to the grant. Repeat Finding Not Applicable. Recommendation We recommend that management develop internal controls for appropriate cutoff of grant expenditures and review to ensure the appropriate costs were charged to the budgeted period to the grant. Views of Responsible Officials of Auditee Management concurs with the finding and has provided the accompanying management corrective action.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.303(a) which requires that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.403 which states except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also § 200.306(b). (g) Be adequately documented. See also §§ 200.300 through 200.309 of this part. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3). State ex rel. McClure v. Hagerman, 155 Ohio St. 320 (1951) provides that expenditures made by a governmental unit should serve a public purpose. Typically, the determination of what constitutes a “proper public purpose” rests with the judgment of the governmental entity, unless such determination is arbitrary or unreasonable. Even if a purchase is reasonable, Ohio Attorney General Opinion 82-006 indicates that it must be memorialized by a duly enacted ordinance or resolution and may have a prospective effect only. Auditor of State Bulletin 2003-005 Expenditure of Public Funds/Proper “Public Purpose” states, in part, the Auditor of State’s Office will only question expenditures where the legislative determination of a public purpose is manifestly arbitrary and incorrect. The Lima-Allen County Regional Planning Commission, administrator of the Community Housing Impact and Preservation Program - CHIP (#B-C-21-1AB-1) for Allen County, incurred a charge of $4,386 for Admin January 2023 charges on invoice #106558 dated February 7, 2023 from the Great Lakes Community Action Partnership. On July 6, 2023, check number 7330652 was issued by Allen County which included payment of $4,386 on invoice number 106558. On August 3, 2023, check number 7332670 was issued by Allen County which included payment of $4,386 on invoice number 106558 which was approved by Tara Bales, Executive Director of the Lima-Allen County Regional Planning Commission. As a result, possibly due to the failure of an existing control or procedure, invoice number 106558 was paid twice resulting an overpayment of $4,386. On October 2, 2024, the Great Lakes Community Action Partnership refunded the overpayment with check number 20765 in the amount of $4,386. This refund was recorded in the Community Development Grant Fund (2414). The Lima-Allen County Regional Planning Commission should implement an additional control(s) and/or procedure(s) to prevent the duplicate payment of invoices.
2023-014 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 grant expenditures outside the grant period. Perspective: Thirty-one 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 2022-017. Recommendation: In order to prevent future occurences of this deficiency, we recommend 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.
2023-014 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 grant expenditures outside the grant period. Perspective: Thirty-one 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 2022-017. Recommendation: In order to prevent future occurences of this deficiency, we recommend 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.
2023-014 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 grant expenditures outside the grant period. Perspective: Thirty-one 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 2022-017. Recommendation: In order to prevent future occurences of this deficiency, we recommend 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.
2023 – 005 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-2302ILLIEA 10/1/2022; G-2202ILLIEA 10/1/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 22-224038 Award Period: June 1, 2023 through September 30, 2024 and October 1, 2021 through June 30, 2023 Type of Finding: • Material Weakness 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 non-federal entities charge only allowable costs incurred during the approved budget period of a general award’s period of performance. Effective internal controls should include procedures to ensure transactions for costs recorded for the beginning of the period of performance were not incurred prior to the start of the period of performance and transactions for cost recorded for the end of the period of performance were not incurred after the end of the period of performance for Federal awards. Condition: The County allocated costs to federal awards prior to the beginning of the period of performance and after the end of the period of performance. Questioned costs: $31,837 Context: 9 of 10 transactions tested were incurred prior to the period of performance and 1 of 15 transactions tested were incurred after the period of performance end date. Cause: Costs were inadvertently claimed that fell outside the period of performance. Effect: May result in unallowable costs being charged to the Federal program. Repeat Finding: This finding is a partial repeat of a finding in the prior year. The prior year finding number was 2022-005. Recommendation: We recommend the County review its procedures relative to allocating costs to Federal programs, and ensure only cost within the grant period are included. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 005 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-2302ILLIEA 10/1/2022; G-2202ILLIEA 10/1/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 22-224038 Award Period: June 1, 2023 through September 30, 2024 and October 1, 2021 through June 30, 2023 Type of Finding: • Material Weakness 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 non-federal entities charge only allowable costs incurred during the approved budget period of a general award’s period of performance. Effective internal controls should include procedures to ensure transactions for costs recorded for the beginning of the period of performance were not incurred prior to the start of the period of performance and transactions for cost recorded for the end of the period of performance were not incurred after the end of the period of performance for Federal awards. Condition: The County allocated costs to federal awards prior to the beginning of the period of performance and after the end of the period of performance. Questioned costs: $31,837 Context: 9 of 10 transactions tested were incurred prior to the period of performance and 1 of 15 transactions tested were incurred after the period of performance end date. Cause: Costs were inadvertently claimed that fell outside the period of performance. Effect: May result in unallowable costs being charged to the Federal program. Repeat Finding: This finding is a partial repeat of a finding in the prior year. The prior year finding number was 2022-005. Recommendation: We recommend the County review its procedures relative to allocating costs to Federal programs, and ensure only cost within the grant period are included. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 005 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-2302ILLIEA 10/1/2022; G-2202ILLIEA 10/1/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 22-224038 Award Period: June 1, 2023 through September 30, 2024 and October 1, 2021 through June 30, 2023 Type of Finding: • Material Weakness 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 non-federal entities charge only allowable costs incurred during the approved budget period of a general award’s period of performance. Effective internal controls should include procedures to ensure transactions for costs recorded for the beginning of the period of performance were not incurred prior to the start of the period of performance and transactions for cost recorded for the end of the period of performance were not incurred after the end of the period of performance for Federal awards. Condition: The County allocated costs to federal awards prior to the beginning of the period of performance and after the end of the period of performance. Questioned costs: $31,837 Context: 9 of 10 transactions tested were incurred prior to the period of performance and 1 of 15 transactions tested were incurred after the period of performance end date. Cause: Costs were inadvertently claimed that fell outside the period of performance. Effect: May result in unallowable costs being charged to the Federal program. Repeat Finding: This finding is a partial repeat of a finding in the prior year. The prior year finding number was 2022-005. Recommendation: We recommend the County review its procedures relative to allocating costs to Federal programs, and ensure only cost within the grant period are included. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 005 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-2302ILLIEA 10/1/2022; G-2202ILLIEA 10/1/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 22-224038 Award Period: June 1, 2023 through September 30, 2024 and October 1, 2021 through June 30, 2023 Type of Finding: • Material Weakness 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 non-federal entities charge only allowable costs incurred during the approved budget period of a general award’s period of performance. Effective internal controls should include procedures to ensure transactions for costs recorded for the beginning of the period of performance were not incurred prior to the start of the period of performance and transactions for cost recorded for the end of the period of performance were not incurred after the end of the period of performance for Federal awards. Condition: The County allocated costs to federal awards prior to the beginning of the period of performance and after the end of the period of performance. Questioned costs: $31,837 Context: 9 of 10 transactions tested were incurred prior to the period of performance and 1 of 15 transactions tested were incurred after the period of performance end date. Cause: Costs were inadvertently claimed that fell outside the period of performance. Effect: May result in unallowable costs being charged to the Federal program. Repeat Finding: This finding is a partial repeat of a finding in the prior year. The prior year finding number was 2022-005. Recommendation: We recommend the County review its procedures relative to allocating costs to Federal programs, and ensure only cost within the grant period are included. Views of responsible officials: There is no disagreement with the audit finding.
2023-001 – Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Information on Federal Program(s) - Department of Education Assistance Listing Number: 84.351 Assistance Listing Name: Arts in Education National Program Grant Award Numbers: S351A220007 Award Period: October 1, 2022 to September 30, 2023 Criteria or Specific Requirement – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In addition, per 2 CFR Section 200.403, “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federallyfinanced program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3).” Condition – In evaluating the Center’s compliance with the requirements of Activities Allowed or Unallowed and Allowable Costs Cost Principles, our test work identified two instances out of a sample of sixty payroll transactions, totaling $41,872.98, in which employees were not paid according to their contract. For the two exceptions, the employees were underpaid a total of $1.48. Cause – The Center did not adhere to their internal process to ensure approved salary information was accurately applied. Effect or Potential Effect – Without adequate internal controls in place to ensure costs are properly verified and applied, the Center could inaccurately charge expenditures to the federal program. Questioned Costs – N/A Context – This is a condition based on testing of the Center’s compliance. Based on tested samples, we noted a total underpayment of $1.48. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding – This is a repeat finding from prior year. While the prior year finding resulted in a net overpayment and current year finding resulted in a net underpayment, the fact that management is not adhering to their internal control processes requires this finding to be considered a repeat finding. This was reported as finding 2022-002 in the 2022 report. Recommendation - We recommend management ensure the Center strengthen their internal process to ensure that employee salary information recorded in the payroll system are approved, supported by salary documentation in the personnel files, and accurately applied. Views of Responsible Officials – After performing a detailed analysis, the Center’s management identified that the likely net underpayment amounted to $111.52, while the likely net overpayment was $83.20. The likely underpayment and overpayment were determined by management through examination of the total salary charged to the federal program. The Center’s management agrees with the finding and will strengthen the internal process surrounding the activities allowed or unallowed and allowable costs and will ensure adequate documentation is in place and approved salary rates are consistently and properly applied. See the Center’s corrective action for more details.
2023-001 – Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Information on Federal Program(s) - Department of Education Assistance Listing Number: 84.351 Assistance Listing Name: Arts in Education National Program Grant Award Numbers: S351A220007 Award Period: October 1, 2022 to September 30, 2023 Criteria or Specific Requirement – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In addition, per 2 CFR Section 200.403, “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federallyfinanced program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3).” Condition – In evaluating the Center’s compliance with the requirements of Activities Allowed or Unallowed and Allowable Costs Cost Principles, our test work identified two instances out of a sample of sixty payroll transactions, totaling $41,872.98, in which employees were not paid according to their contract. For the two exceptions, the employees were underpaid a total of $1.48. Cause – The Center did not adhere to their internal process to ensure approved salary information was accurately applied. Effect or Potential Effect – Without adequate internal controls in place to ensure costs are properly verified and applied, the Center could inaccurately charge expenditures to the federal program. Questioned Costs – N/A Context – This is a condition based on testing of the Center’s compliance. Based on tested samples, we noted a total underpayment of $1.48. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding – This is a repeat finding from prior year. While the prior year finding resulted in a net overpayment and current year finding resulted in a net underpayment, the fact that management is not adhering to their internal control processes requires this finding to be considered a repeat finding. This was reported as finding 2022-002 in the 2022 report. Recommendation - We recommend management ensure the Center strengthen their internal process to ensure that employee salary information recorded in the payroll system are approved, supported by salary documentation in the personnel files, and accurately applied. Views of Responsible Officials – After performing a detailed analysis, the Center’s management identified that the likely net underpayment amounted to $111.52, while the likely net overpayment was $83.20. The likely underpayment and overpayment were determined by management through examination of the total salary charged to the federal program. The Center’s management agrees with the finding and will strengthen the internal process surrounding the activities allowed or unallowed and allowable costs and will ensure adequate documentation is in place and approved salary rates are consistently and properly applied. See the Center’s corrective action for more details.
DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-004 Immunization Cooperative Agreements, ALN #93.268 Criteria: According to 2 CFR Section 200.308, all budget revisions over 10% must receive a budget revision from the grantee. Condition: Following a budget revision of over 10%, an approval was not received from the grantee. Cause: At direction from the pass-through agency, the Organization charged salary expenses to the contract services line items on its request reimbursement instead of getting budget revisions to reflect the change in the work performed. Effect: The costs billed on the vouchers for reimbursement, did not match the natural classification of the actual expenses incurred on the grant resulting in expenses reported being over budget on certain line items and under budget on others. Auditor recommendation: We recommend that when there is a budget revision over 10%, the Organization works with the grantor to get formal documentation to support the revision to ensure amounts charged to the grants are in line with budget line items. Management response: Management will ensure a budget revision be done for any increase over 10% and submit that to the grantor to receive formal approval from the grantor.
Prior Year Finding Number: 2022-002 Compliance Requirement: Allowable Costs/Cost Principles Program: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Pass through Entity: District of Columbia Office of the Deputy Mayor for Education -Office of Out of School Times Grant and Youth Outcomes, District of Columbia Human Services Rehousing Stabilization Program - Safe Passage Safe Blocks, D.C. Office of the Deputy Mayor Office Victim Services and Justice Grants and Office of Victim Services and Justice Grants Successful Reentry Program CFDA #: 21.027 Award #: 2023-SPSB-011-CSC, 2023-CSC-04, CW1010626, and 2023-AARPA-2004 Award Year: 10/01/2022-09/30/2023! Criteria: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.430 – Factors Affecting Allowability of Costs - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3). The Personnel Section of the Executed Contract indicated specifies that: A. All staff, volunteers, and contractors, collectively called program personnel, who have regular unsupervised contact and direct interactions with youth, must possess the requisite training, qualifications, clearances, and competency to perform the duties to which they are assigned. B. All program personnel must have the following background checks in order to comply with the District of Columbia’s Criminal Background Checks for the Protection of Children Act of 2004. DC Code §§ 4-1501.01 – 4-1501.11 and other OST Office requirements: • DC Child and Family Services Agency (CFSA) Child Protection Registry (CPR); • Federal Bureau of Investigation (FBI) Criminal Background Check; • Metropolitan Police Department (MPD) Criminal Background Check; and • National Sex Offender Registry. C. Any program personnel with the following felony convictions are not permitted to work or volunteer with children and youth: 1. Murder, attempted murder, manslaughter or arson; 2. Assault, battery, assault and battery, assault with a dangerous weapon, mayhem, or threats to do bodily harm; 3. Burglary; 4. Robbery; 5. Kidnapping; 6. Illegal use or possession of a firearm; 7. Sexual offenses, including indecent exposure; promoting, procuring, compelling, soliciting, or engaging in prostitution; corrupting minors (sexual relations with children); molesting; voyeurism; committing sex acts in public; incest; rape; sexual assault; sexual battery; or sexual abuse; but excluding sodomy between consenting adults; 8. Child abuse or cruelty to children; or 9. Unlawful distribution or possession of or possession with intent to distribute, a controlled substance. Condition: We sampled 60 payroll expense transactions and noted the following: • Four (4) instances in which time charged to this program was not recorded in the timesheets reviewed for the periods tested. The total of these transactions were $12,087. • Six (6) payroll transactions did not satisfy the prohibited felony background requirements as specified in the Safe Passage Safe Block grant agreement for personnel hired under this award. The total of these transactions were $16,404. • Six (6) payroll transactions from the Safe Passage Safe Block award did not show evidence of clearance by the D.C. Child and Family Services Child Protection Registry (CPR) and 2 CPRs provided were outside of the period tested. In addition, 5 CPR and First Aid training documentation were not provided. The total of these transactions were $15,585. Two (2) files did not show evidence of Metropolitan Police Department (MPD) criminal background checks as a condition for employment. Eight (8) MPD files requested were not provided. The total of these transactions were $39,102. Twenty-two (22) National Sex Offenders Registry records were not provided for persons hired under the program. This registry was managed directly by a District Agency and was not submitted to CSC. The total of these transactions were $71,408. Questioned Costs: $154,586 Context: This is a condition identified per review of CSC’s compliance with the specified requirements using a statistically valid sample. The known amount of the payroll transactions totaled $154,586. Effect: CSC is not in compliance with the stated provisions of the grant awards. Failure to properly review and support expenses can result in noncompliance with laws and regulations along with loss of funding. Cause: CSC did not appear to have adequate policies and procedures in place to ensure compliance with the required stipulations regarding background. Recommendation: We recommend that CSC ensure that personnel hired under the grant meet all the background and other checks within the stipulated time frame outlined in the grant agreement. We also recommend that CSC improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for expenses incurred and reported.
Prior Year Finding Number: 2022-002 Compliance Requirement: Allowable Costs/Cost Principles Program: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Pass through Entity: District of Columbia Office of the Deputy Mayor for Education -Office of Out of School Times Grant and Youth Outcomes, District of Columbia Human Services Rehousing Stabilization Program - Safe Passage Safe Blocks, D.C. Office of the Deputy Mayor Office Victim Services and Justice Grants and Office of Victim Services and Justice Grants Successful Reentry Program CFDA #: 21.027 Award #: 2023-SPSB-011-CSC, 2023-CSC-04, CW1010626, and 2023-AARPA-2004 Award Year: 10/01/2022-09/30/2023! Criteria: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.430 – Factors Affecting Allowability of Costs - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3). The Personnel Section of the Executed Contract indicated specifies that: A. All staff, volunteers, and contractors, collectively called program personnel, who have regular unsupervised contact and direct interactions with youth, must possess the requisite training, qualifications, clearances, and competency to perform the duties to which they are assigned. B. All program personnel must have the following background checks in order to comply with the District of Columbia’s Criminal Background Checks for the Protection of Children Act of 2004. DC Code §§ 4-1501.01 – 4-1501.11 and other OST Office requirements: • DC Child and Family Services Agency (CFSA) Child Protection Registry (CPR); • Federal Bureau of Investigation (FBI) Criminal Background Check; • Metropolitan Police Department (MPD) Criminal Background Check; and • National Sex Offender Registry. C. Any program personnel with the following felony convictions are not permitted to work or volunteer with children and youth: 1. Murder, attempted murder, manslaughter or arson; 2. Assault, battery, assault and battery, assault with a dangerous weapon, mayhem, or threats to do bodily harm; 3. Burglary; 4. Robbery; 5. Kidnapping; 6. Illegal use or possession of a firearm; 7. Sexual offenses, including indecent exposure; promoting, procuring, compelling, soliciting, or engaging in prostitution; corrupting minors (sexual relations with children); molesting; voyeurism; committing sex acts in public; incest; rape; sexual assault; sexual battery; or sexual abuse; but excluding sodomy between consenting adults; 8. Child abuse or cruelty to children; or 9. Unlawful distribution or possession of or possession with intent to distribute, a controlled substance. Condition: We sampled 60 payroll expense transactions and noted the following: • Four (4) instances in which time charged to this program was not recorded in the timesheets reviewed for the periods tested. The total of these transactions were $12,087. • Six (6) payroll transactions did not satisfy the prohibited felony background requirements as specified in the Safe Passage Safe Block grant agreement for personnel hired under this award. The total of these transactions were $16,404. • Six (6) payroll transactions from the Safe Passage Safe Block award did not show evidence of clearance by the D.C. Child and Family Services Child Protection Registry (CPR) and 2 CPRs provided were outside of the period tested. In addition, 5 CPR and First Aid training documentation were not provided. The total of these transactions were $15,585. Two (2) files did not show evidence of Metropolitan Police Department (MPD) criminal background checks as a condition for employment. Eight (8) MPD files requested were not provided. The total of these transactions were $39,102. Twenty-two (22) National Sex Offenders Registry records were not provided for persons hired under the program. This registry was managed directly by a District Agency and was not submitted to CSC. The total of these transactions were $71,408. Questioned Costs: $154,586 Context: This is a condition identified per review of CSC’s compliance with the specified requirements using a statistically valid sample. The known amount of the payroll transactions totaled $154,586. Effect: CSC is not in compliance with the stated provisions of the grant awards. Failure to properly review and support expenses can result in noncompliance with laws and regulations along with loss of funding. Cause: CSC did not appear to have adequate policies and procedures in place to ensure compliance with the required stipulations regarding background. Recommendation: We recommend that CSC ensure that personnel hired under the grant meet all the background and other checks within the stipulated time frame outlined in the grant agreement. We also recommend that CSC improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for expenses incurred and reported.
Prior Year Finding Number: 2022-002 Compliance Requirement: Allowable Costs/Cost Principles Program: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Pass through Entity: District of Columbia Office of the Deputy Mayor for Education -Office of Out of School Times Grant and Youth Outcomes, District of Columbia Human Services Rehousing Stabilization Program - Safe Passage Safe Blocks, D.C. Office of the Deputy Mayor Office Victim Services and Justice Grants and Office of Victim Services and Justice Grants Successful Reentry Program CFDA #: 21.027 Award #: 2023-SPSB-011-CSC, 2023-CSC-04, CW1010626, and 2023-AARPA-2004 Award Year: 10/01/2022-09/30/2023! Criteria: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.430 – Factors Affecting Allowability of Costs - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3). The Personnel Section of the Executed Contract indicated specifies that: A. All staff, volunteers, and contractors, collectively called program personnel, who have regular unsupervised contact and direct interactions with youth, must possess the requisite training, qualifications, clearances, and competency to perform the duties to which they are assigned. B. All program personnel must have the following background checks in order to comply with the District of Columbia’s Criminal Background Checks for the Protection of Children Act of 2004. DC Code §§ 4-1501.01 – 4-1501.11 and other OST Office requirements: • DC Child and Family Services Agency (CFSA) Child Protection Registry (CPR); • Federal Bureau of Investigation (FBI) Criminal Background Check; • Metropolitan Police Department (MPD) Criminal Background Check; and • National Sex Offender Registry. C. Any program personnel with the following felony convictions are not permitted to work or volunteer with children and youth: 1. Murder, attempted murder, manslaughter or arson; 2. Assault, battery, assault and battery, assault with a dangerous weapon, mayhem, or threats to do bodily harm; 3. Burglary; 4. Robbery; 5. Kidnapping; 6. Illegal use or possession of a firearm; 7. Sexual offenses, including indecent exposure; promoting, procuring, compelling, soliciting, or engaging in prostitution; corrupting minors (sexual relations with children); molesting; voyeurism; committing sex acts in public; incest; rape; sexual assault; sexual battery; or sexual abuse; but excluding sodomy between consenting adults; 8. Child abuse or cruelty to children; or 9. Unlawful distribution or possession of or possession with intent to distribute, a controlled substance. Condition: We sampled 60 payroll expense transactions and noted the following: • Four (4) instances in which time charged to this program was not recorded in the timesheets reviewed for the periods tested. The total of these transactions were $12,087. • Six (6) payroll transactions did not satisfy the prohibited felony background requirements as specified in the Safe Passage Safe Block grant agreement for personnel hired under this award. The total of these transactions were $16,404. • Six (6) payroll transactions from the Safe Passage Safe Block award did not show evidence of clearance by the D.C. Child and Family Services Child Protection Registry (CPR) and 2 CPRs provided were outside of the period tested. In addition, 5 CPR and First Aid training documentation were not provided. The total of these transactions were $15,585. Two (2) files did not show evidence of Metropolitan Police Department (MPD) criminal background checks as a condition for employment. Eight (8) MPD files requested were not provided. The total of these transactions were $39,102. Twenty-two (22) National Sex Offenders Registry records were not provided for persons hired under the program. This registry was managed directly by a District Agency and was not submitted to CSC. The total of these transactions were $71,408. Questioned Costs: $154,586 Context: This is a condition identified per review of CSC’s compliance with the specified requirements using a statistically valid sample. The known amount of the payroll transactions totaled $154,586. Effect: CSC is not in compliance with the stated provisions of the grant awards. Failure to properly review and support expenses can result in noncompliance with laws and regulations along with loss of funding. Cause: CSC did not appear to have adequate policies and procedures in place to ensure compliance with the required stipulations regarding background. Recommendation: We recommend that CSC ensure that personnel hired under the grant meet all the background and other checks within the stipulated time frame outlined in the grant agreement. We also recommend that CSC improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for expenses incurred and reported.
Prior Year Finding Number: 2022-002 Compliance Requirement: Allowable Costs/Cost Principles Program: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Pass through Entity: District of Columbia Office of the Deputy Mayor for Education -Office of Out of School Times Grant and Youth Outcomes, District of Columbia Human Services Rehousing Stabilization Program - Safe Passage Safe Blocks, D.C. Office of the Deputy Mayor Office Victim Services and Justice Grants and Office of Victim Services and Justice Grants Successful Reentry Program CFDA #: 21.027 Award #: 2023-SPSB-011-CSC, 2023-CSC-04, CW1010626, and 2023-AARPA-2004 Award Year: 10/01/2022-09/30/2023! Criteria: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.430 – Factors Affecting Allowability of Costs - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3). The Personnel Section of the Executed Contract indicated specifies that: A. All staff, volunteers, and contractors, collectively called program personnel, who have regular unsupervised contact and direct interactions with youth, must possess the requisite training, qualifications, clearances, and competency to perform the duties to which they are assigned. B. All program personnel must have the following background checks in order to comply with the District of Columbia’s Criminal Background Checks for the Protection of Children Act of 2004. DC Code §§ 4-1501.01 – 4-1501.11 and other OST Office requirements: • DC Child and Family Services Agency (CFSA) Child Protection Registry (CPR); • Federal Bureau of Investigation (FBI) Criminal Background Check; • Metropolitan Police Department (MPD) Criminal Background Check; and • National Sex Offender Registry. C. Any program personnel with the following felony convictions are not permitted to work or volunteer with children and youth: 1. Murder, attempted murder, manslaughter or arson; 2. Assault, battery, assault and battery, assault with a dangerous weapon, mayhem, or threats to do bodily harm; 3. Burglary; 4. Robbery; 5. Kidnapping; 6. Illegal use or possession of a firearm; 7. Sexual offenses, including indecent exposure; promoting, procuring, compelling, soliciting, or engaging in prostitution; corrupting minors (sexual relations with children); molesting; voyeurism; committing sex acts in public; incest; rape; sexual assault; sexual battery; or sexual abuse; but excluding sodomy between consenting adults; 8. Child abuse or cruelty to children; or 9. Unlawful distribution or possession of or possession with intent to distribute, a controlled substance. Condition: We sampled 60 payroll expense transactions and noted the following: • Four (4) instances in which time charged to this program was not recorded in the timesheets reviewed for the periods tested. The total of these transactions were $12,087. • Six (6) payroll transactions did not satisfy the prohibited felony background requirements as specified in the Safe Passage Safe Block grant agreement for personnel hired under this award. The total of these transactions were $16,404. • Six (6) payroll transactions from the Safe Passage Safe Block award did not show evidence of clearance by the D.C. Child and Family Services Child Protection Registry (CPR) and 2 CPRs provided were outside of the period tested. In addition, 5 CPR and First Aid training documentation were not provided. The total of these transactions were $15,585. Two (2) files did not show evidence of Metropolitan Police Department (MPD) criminal background checks as a condition for employment. Eight (8) MPD files requested were not provided. The total of these transactions were $39,102. Twenty-two (22) National Sex Offenders Registry records were not provided for persons hired under the program. This registry was managed directly by a District Agency and was not submitted to CSC. The total of these transactions were $71,408. Questioned Costs: $154,586 Context: This is a condition identified per review of CSC’s compliance with the specified requirements using a statistically valid sample. The known amount of the payroll transactions totaled $154,586. Effect: CSC is not in compliance with the stated provisions of the grant awards. Failure to properly review and support expenses can result in noncompliance with laws and regulations along with loss of funding. Cause: CSC did not appear to have adequate policies and procedures in place to ensure compliance with the required stipulations regarding background. Recommendation: We recommend that CSC ensure that personnel hired under the grant meet all the background and other checks within the stipulated time frame outlined in the grant agreement. We also recommend that CSC improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for expenses incurred and reported.
Prior Year Finding Number: 2022-002 Compliance Requirement: Allowable Costs/Cost Principles Program: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Pass through Entity: District of Columbia Office of the Deputy Mayor for Education -Office of Out of School Times Grant and Youth Outcomes, District of Columbia Human Services Rehousing Stabilization Program - Safe Passage Safe Blocks, D.C. Office of the Deputy Mayor Office Victim Services and Justice Grants and Office of Victim Services and Justice Grants Successful Reentry Program CFDA #: 21.027 Award #: 2023-SPSB-011-CSC, 2023-CSC-04, CW1010626, and 2023-AARPA-2004 Award Year: 10/01/2022-09/30/2023! Criteria: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.430 – Factors Affecting Allowability of Costs - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3). The Personnel Section of the Executed Contract indicated specifies that: A. All staff, volunteers, and contractors, collectively called program personnel, who have regular unsupervised contact and direct interactions with youth, must possess the requisite training, qualifications, clearances, and competency to perform the duties to which they are assigned. B. All program personnel must have the following background checks in order to comply with the District of Columbia’s Criminal Background Checks for the Protection of Children Act of 2004. DC Code §§ 4-1501.01 – 4-1501.11 and other OST Office requirements: • DC Child and Family Services Agency (CFSA) Child Protection Registry (CPR); • Federal Bureau of Investigation (FBI) Criminal Background Check; • Metropolitan Police Department (MPD) Criminal Background Check; and • National Sex Offender Registry. C. Any program personnel with the following felony convictions are not permitted to work or volunteer with children and youth: 1. Murder, attempted murder, manslaughter or arson; 2. Assault, battery, assault and battery, assault with a dangerous weapon, mayhem, or threats to do bodily harm; 3. Burglary; 4. Robbery; 5. Kidnapping; 6. Illegal use or possession of a firearm; 7. Sexual offenses, including indecent exposure; promoting, procuring, compelling, soliciting, or engaging in prostitution; corrupting minors (sexual relations with children); molesting; voyeurism; committing sex acts in public; incest; rape; sexual assault; sexual battery; or sexual abuse; but excluding sodomy between consenting adults; 8. Child abuse or cruelty to children; or 9. Unlawful distribution or possession of or possession with intent to distribute, a controlled substance. Condition: We sampled 60 payroll expense transactions and noted the following: • Four (4) instances in which time charged to this program was not recorded in the timesheets reviewed for the periods tested. The total of these transactions were $12,087. • Six (6) payroll transactions did not satisfy the prohibited felony background requirements as specified in the Safe Passage Safe Block grant agreement for personnel hired under this award. The total of these transactions were $16,404. • Six (6) payroll transactions from the Safe Passage Safe Block award did not show evidence of clearance by the D.C. Child and Family Services Child Protection Registry (CPR) and 2 CPRs provided were outside of the period tested. In addition, 5 CPR and First Aid training documentation were not provided. The total of these transactions were $15,585. Two (2) files did not show evidence of Metropolitan Police Department (MPD) criminal background checks as a condition for employment. Eight (8) MPD files requested were not provided. The total of these transactions were $39,102. Twenty-two (22) National Sex Offenders Registry records were not provided for persons hired under the program. This registry was managed directly by a District Agency and was not submitted to CSC. The total of these transactions were $71,408. Questioned Costs: $154,586 Context: This is a condition identified per review of CSC’s compliance with the specified requirements using a statistically valid sample. The known amount of the payroll transactions totaled $154,586. Effect: CSC is not in compliance with the stated provisions of the grant awards. Failure to properly review and support expenses can result in noncompliance with laws and regulations along with loss of funding. Cause: CSC did not appear to have adequate policies and procedures in place to ensure compliance with the required stipulations regarding background. Recommendation: We recommend that CSC ensure that personnel hired under the grant meet all the background and other checks within the stipulated time frame outlined in the grant agreement. We also recommend that CSC improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for expenses incurred and reported.
DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-004 Immunization Cooperative Agreements, ALN #93.268 Criteria: According to 2 CFR Section 200.308, all budget revisions over 10% must receive a budget revision from the grantee. Condition: Following a budget revision of over 10%, an approval was not received from the grantee. Cause: At direction from the pass-through agency, the Organization charged salary expenses to the contract services line items on its request reimbursement instead of getting budget revisions to reflect the change in the work performed. Effect: The costs billed on the vouchers for reimbursement, did not match the natural classification of the actual expenses incurred on the grant resulting in expenses reported being over budget on certain line items and under budget on others. Auditor recommendation: We recommend that when there is a budget revision over 10%, the Organization works with the grantor to get formal documentation to support the revision to ensure amounts charged to the grants are in line with budget line items. Management response: Management will ensure a budget revision be done for any increase over 10% and submit that to the grantor to receive formal approval from the grantor.
Prior Year Finding Number: 2022-002 Compliance Requirement: Allowable Costs/Cost Principles Program: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Pass through Entity: District of Columbia Office of the Deputy Mayor for Education -Office of Out of School Times Grant and Youth Outcomes, District of Columbia Human Services Rehousing Stabilization Program - Safe Passage Safe Blocks, D.C. Office of the Deputy Mayor Office Victim Services and Justice Grants and Office of Victim Services and Justice Grants Successful Reentry Program CFDA #: 21.027 Award #: 2023-SPSB-011-CSC, 2023-CSC-04, CW1010626, and 2023-AARPA-2004 Award Year: 10/01/2022-09/30/2023! Criteria: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.430 – Factors Affecting Allowability of Costs - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3). The Personnel Section of the Executed Contract indicated specifies that: A. All staff, volunteers, and contractors, collectively called program personnel, who have regular unsupervised contact and direct interactions with youth, must possess the requisite training, qualifications, clearances, and competency to perform the duties to which they are assigned. B. All program personnel must have the following background checks in order to comply with the District of Columbia’s Criminal Background Checks for the Protection of Children Act of 2004. DC Code §§ 4-1501.01 – 4-1501.11 and other OST Office requirements: • DC Child and Family Services Agency (CFSA) Child Protection Registry (CPR); • Federal Bureau of Investigation (FBI) Criminal Background Check; • Metropolitan Police Department (MPD) Criminal Background Check; and • National Sex Offender Registry. C. Any program personnel with the following felony convictions are not permitted to work or volunteer with children and youth: 1. Murder, attempted murder, manslaughter or arson; 2. Assault, battery, assault and battery, assault with a dangerous weapon, mayhem, or threats to do bodily harm; 3. Burglary; 4. Robbery; 5. Kidnapping; 6. Illegal use or possession of a firearm; 7. Sexual offenses, including indecent exposure; promoting, procuring, compelling, soliciting, or engaging in prostitution; corrupting minors (sexual relations with children); molesting; voyeurism; committing sex acts in public; incest; rape; sexual assault; sexual battery; or sexual abuse; but excluding sodomy between consenting adults; 8. Child abuse or cruelty to children; or 9. Unlawful distribution or possession of or possession with intent to distribute, a controlled substance. Condition: We sampled 60 payroll expense transactions and noted the following: • Four (4) instances in which time charged to this program was not recorded in the timesheets reviewed for the periods tested. The total of these transactions were $12,087. • Six (6) payroll transactions did not satisfy the prohibited felony background requirements as specified in the Safe Passage Safe Block grant agreement for personnel hired under this award. The total of these transactions were $16,404. • Six (6) payroll transactions from the Safe Passage Safe Block award did not show evidence of clearance by the D.C. Child and Family Services Child Protection Registry (CPR) and 2 CPRs provided were outside of the period tested. In addition, 5 CPR and First Aid training documentation were not provided. The total of these transactions were $15,585. Two (2) files did not show evidence of Metropolitan Police Department (MPD) criminal background checks as a condition for employment. Eight (8) MPD files requested were not provided. The total of these transactions were $39,102. Twenty-two (22) National Sex Offenders Registry records were not provided for persons hired under the program. This registry was managed directly by a District Agency and was not submitted to CSC. The total of these transactions were $71,408. Questioned Costs: $154,586 Context: This is a condition identified per review of CSC’s compliance with the specified requirements using a statistically valid sample. The known amount of the payroll transactions totaled $154,586. Effect: CSC is not in compliance with the stated provisions of the grant awards. Failure to properly review and support expenses can result in noncompliance with laws and regulations along with loss of funding. Cause: CSC did not appear to have adequate policies and procedures in place to ensure compliance with the required stipulations regarding background. Recommendation: We recommend that CSC ensure that personnel hired under the grant meet all the background and other checks within the stipulated time frame outlined in the grant agreement. We also recommend that CSC improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for expenses incurred and reported.
Prior Year Finding Number: 2022-002 Compliance Requirement: Allowable Costs/Cost Principles Program: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Pass through Entity: District of Columbia Office of the Deputy Mayor for Education -Office of Out of School Times Grant and Youth Outcomes, District of Columbia Human Services Rehousing Stabilization Program - Safe Passage Safe Blocks, D.C. Office of the Deputy Mayor Office Victim Services and Justice Grants and Office of Victim Services and Justice Grants Successful Reentry Program CFDA #: 21.027 Award #: 2023-SPSB-011-CSC, 2023-CSC-04, CW1010626, and 2023-AARPA-2004 Award Year: 10/01/2022-09/30/2023! Criteria: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.430 – Factors Affecting Allowability of Costs - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3). The Personnel Section of the Executed Contract indicated specifies that: A. All staff, volunteers, and contractors, collectively called program personnel, who have regular unsupervised contact and direct interactions with youth, must possess the requisite training, qualifications, clearances, and competency to perform the duties to which they are assigned. B. All program personnel must have the following background checks in order to comply with the District of Columbia’s Criminal Background Checks for the Protection of Children Act of 2004. DC Code §§ 4-1501.01 – 4-1501.11 and other OST Office requirements: • DC Child and Family Services Agency (CFSA) Child Protection Registry (CPR); • Federal Bureau of Investigation (FBI) Criminal Background Check; • Metropolitan Police Department (MPD) Criminal Background Check; and • National Sex Offender Registry. C. Any program personnel with the following felony convictions are not permitted to work or volunteer with children and youth: 1. Murder, attempted murder, manslaughter or arson; 2. Assault, battery, assault and battery, assault with a dangerous weapon, mayhem, or threats to do bodily harm; 3. Burglary; 4. Robbery; 5. Kidnapping; 6. Illegal use or possession of a firearm; 7. Sexual offenses, including indecent exposure; promoting, procuring, compelling, soliciting, or engaging in prostitution; corrupting minors (sexual relations with children); molesting; voyeurism; committing sex acts in public; incest; rape; sexual assault; sexual battery; or sexual abuse; but excluding sodomy between consenting adults; 8. Child abuse or cruelty to children; or 9. Unlawful distribution or possession of or possession with intent to distribute, a controlled substance. Condition: We sampled 60 payroll expense transactions and noted the following: • Four (4) instances in which time charged to this program was not recorded in the timesheets reviewed for the periods tested. The total of these transactions were $12,087. • Six (6) payroll transactions did not satisfy the prohibited felony background requirements as specified in the Safe Passage Safe Block grant agreement for personnel hired under this award. The total of these transactions were $16,404. • Six (6) payroll transactions from the Safe Passage Safe Block award did not show evidence of clearance by the D.C. Child and Family Services Child Protection Registry (CPR) and 2 CPRs provided were outside of the period tested. In addition, 5 CPR and First Aid training documentation were not provided. The total of these transactions were $15,585. Two (2) files did not show evidence of Metropolitan Police Department (MPD) criminal background checks as a condition for employment. Eight (8) MPD files requested were not provided. The total of these transactions were $39,102. Twenty-two (22) National Sex Offenders Registry records were not provided for persons hired under the program. This registry was managed directly by a District Agency and was not submitted to CSC. The total of these transactions were $71,408. Questioned Costs: $154,586 Context: This is a condition identified per review of CSC’s compliance with the specified requirements using a statistically valid sample. The known amount of the payroll transactions totaled $154,586. Effect: CSC is not in compliance with the stated provisions of the grant awards. Failure to properly review and support expenses can result in noncompliance with laws and regulations along with loss of funding. Cause: CSC did not appear to have adequate policies and procedures in place to ensure compliance with the required stipulations regarding background. Recommendation: We recommend that CSC ensure that personnel hired under the grant meet all the background and other checks within the stipulated time frame outlined in the grant agreement. We also recommend that CSC improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for expenses incurred and reported.
Prior Year Finding Number: 2022-002 Compliance Requirement: Allowable Costs/Cost Principles Program: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Pass through Entity: District of Columbia Office of the Deputy Mayor for Education -Office of Out of School Times Grant and Youth Outcomes, District of Columbia Human Services Rehousing Stabilization Program - Safe Passage Safe Blocks, D.C. Office of the Deputy Mayor Office Victim Services and Justice Grants and Office of Victim Services and Justice Grants Successful Reentry Program CFDA #: 21.027 Award #: 2023-SPSB-011-CSC, 2023-CSC-04, CW1010626, and 2023-AARPA-2004 Award Year: 10/01/2022-09/30/2023! Criteria: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.430 – Factors Affecting Allowability of Costs - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3). The Personnel Section of the Executed Contract indicated specifies that: A. All staff, volunteers, and contractors, collectively called program personnel, who have regular unsupervised contact and direct interactions with youth, must possess the requisite training, qualifications, clearances, and competency to perform the duties to which they are assigned. B. All program personnel must have the following background checks in order to comply with the District of Columbia’s Criminal Background Checks for the Protection of Children Act of 2004. DC Code §§ 4-1501.01 – 4-1501.11 and other OST Office requirements: • DC Child and Family Services Agency (CFSA) Child Protection Registry (CPR); • Federal Bureau of Investigation (FBI) Criminal Background Check; • Metropolitan Police Department (MPD) Criminal Background Check; and • National Sex Offender Registry. C. Any program personnel with the following felony convictions are not permitted to work or volunteer with children and youth: 1. Murder, attempted murder, manslaughter or arson; 2. Assault, battery, assault and battery, assault with a dangerous weapon, mayhem, or threats to do bodily harm; 3. Burglary; 4. Robbery; 5. Kidnapping; 6. Illegal use or possession of a firearm; 7. Sexual offenses, including indecent exposure; promoting, procuring, compelling, soliciting, or engaging in prostitution; corrupting minors (sexual relations with children); molesting; voyeurism; committing sex acts in public; incest; rape; sexual assault; sexual battery; or sexual abuse; but excluding sodomy between consenting adults; 8. Child abuse or cruelty to children; or 9. Unlawful distribution or possession of or possession with intent to distribute, a controlled substance. Condition: We sampled 60 payroll expense transactions and noted the following: • Four (4) instances in which time charged to this program was not recorded in the timesheets reviewed for the periods tested. The total of these transactions were $12,087. • Six (6) payroll transactions did not satisfy the prohibited felony background requirements as specified in the Safe Passage Safe Block grant agreement for personnel hired under this award. The total of these transactions were $16,404. • Six (6) payroll transactions from the Safe Passage Safe Block award did not show evidence of clearance by the D.C. Child and Family Services Child Protection Registry (CPR) and 2 CPRs provided were outside of the period tested. In addition, 5 CPR and First Aid training documentation were not provided. The total of these transactions were $15,585. Two (2) files did not show evidence of Metropolitan Police Department (MPD) criminal background checks as a condition for employment. Eight (8) MPD files requested were not provided. The total of these transactions were $39,102. Twenty-two (22) National Sex Offenders Registry records were not provided for persons hired under the program. This registry was managed directly by a District Agency and was not submitted to CSC. The total of these transactions were $71,408. Questioned Costs: $154,586 Context: This is a condition identified per review of CSC’s compliance with the specified requirements using a statistically valid sample. The known amount of the payroll transactions totaled $154,586. Effect: CSC is not in compliance with the stated provisions of the grant awards. Failure to properly review and support expenses can result in noncompliance with laws and regulations along with loss of funding. Cause: CSC did not appear to have adequate policies and procedures in place to ensure compliance with the required stipulations regarding background. Recommendation: We recommend that CSC ensure that personnel hired under the grant meet all the background and other checks within the stipulated time frame outlined in the grant agreement. We also recommend that CSC improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for expenses incurred and reported.
Prior Year Finding Number: 2022-002 Compliance Requirement: Allowable Costs/Cost Principles Program: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Pass through Entity: District of Columbia Office of the Deputy Mayor for Education -Office of Out of School Times Grant and Youth Outcomes, District of Columbia Human Services Rehousing Stabilization Program - Safe Passage Safe Blocks, D.C. Office of the Deputy Mayor Office Victim Services and Justice Grants and Office of Victim Services and Justice Grants Successful Reentry Program CFDA #: 21.027 Award #: 2023-SPSB-011-CSC, 2023-CSC-04, CW1010626, and 2023-AARPA-2004 Award Year: 10/01/2022-09/30/2023! Criteria: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.430 – Factors Affecting Allowability of Costs - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3). The Personnel Section of the Executed Contract indicated specifies that: A. All staff, volunteers, and contractors, collectively called program personnel, who have regular unsupervised contact and direct interactions with youth, must possess the requisite training, qualifications, clearances, and competency to perform the duties to which they are assigned. B. All program personnel must have the following background checks in order to comply with the District of Columbia’s Criminal Background Checks for the Protection of Children Act of 2004. DC Code §§ 4-1501.01 – 4-1501.11 and other OST Office requirements: • DC Child and Family Services Agency (CFSA) Child Protection Registry (CPR); • Federal Bureau of Investigation (FBI) Criminal Background Check; • Metropolitan Police Department (MPD) Criminal Background Check; and • National Sex Offender Registry. C. Any program personnel with the following felony convictions are not permitted to work or volunteer with children and youth: 1. Murder, attempted murder, manslaughter or arson; 2. Assault, battery, assault and battery, assault with a dangerous weapon, mayhem, or threats to do bodily harm; 3. Burglary; 4. Robbery; 5. Kidnapping; 6. Illegal use or possession of a firearm; 7. Sexual offenses, including indecent exposure; promoting, procuring, compelling, soliciting, or engaging in prostitution; corrupting minors (sexual relations with children); molesting; voyeurism; committing sex acts in public; incest; rape; sexual assault; sexual battery; or sexual abuse; but excluding sodomy between consenting adults; 8. Child abuse or cruelty to children; or 9. Unlawful distribution or possession of or possession with intent to distribute, a controlled substance. Condition: We sampled 60 payroll expense transactions and noted the following: • Four (4) instances in which time charged to this program was not recorded in the timesheets reviewed for the periods tested. The total of these transactions were $12,087. • Six (6) payroll transactions did not satisfy the prohibited felony background requirements as specified in the Safe Passage Safe Block grant agreement for personnel hired under this award. The total of these transactions were $16,404. • Six (6) payroll transactions from the Safe Passage Safe Block award did not show evidence of clearance by the D.C. Child and Family Services Child Protection Registry (CPR) and 2 CPRs provided were outside of the period tested. In addition, 5 CPR and First Aid training documentation were not provided. The total of these transactions were $15,585. Two (2) files did not show evidence of Metropolitan Police Department (MPD) criminal background checks as a condition for employment. Eight (8) MPD files requested were not provided. The total of these transactions were $39,102. Twenty-two (22) National Sex Offenders Registry records were not provided for persons hired under the program. This registry was managed directly by a District Agency and was not submitted to CSC. The total of these transactions were $71,408. Questioned Costs: $154,586 Context: This is a condition identified per review of CSC’s compliance with the specified requirements using a statistically valid sample. The known amount of the payroll transactions totaled $154,586. Effect: CSC is not in compliance with the stated provisions of the grant awards. Failure to properly review and support expenses can result in noncompliance with laws and regulations along with loss of funding. Cause: CSC did not appear to have adequate policies and procedures in place to ensure compliance with the required stipulations regarding background. Recommendation: We recommend that CSC ensure that personnel hired under the grant meet all the background and other checks within the stipulated time frame outlined in the grant agreement. We also recommend that CSC improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for expenses incurred and reported.
Prior Year Finding Number: 2022-002 Compliance Requirement: Allowable Costs/Cost Principles Program: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Pass through Entity: District of Columbia Office of the Deputy Mayor for Education -Office of Out of School Times Grant and Youth Outcomes, District of Columbia Human Services Rehousing Stabilization Program - Safe Passage Safe Blocks, D.C. Office of the Deputy Mayor Office Victim Services and Justice Grants and Office of Victim Services and Justice Grants Successful Reentry Program CFDA #: 21.027 Award #: 2023-SPSB-011-CSC, 2023-CSC-04, CW1010626, and 2023-AARPA-2004 Award Year: 10/01/2022-09/30/2023! Criteria: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.430 – Factors Affecting Allowability of Costs - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3). The Personnel Section of the Executed Contract indicated specifies that: A. All staff, volunteers, and contractors, collectively called program personnel, who have regular unsupervised contact and direct interactions with youth, must possess the requisite training, qualifications, clearances, and competency to perform the duties to which they are assigned. B. All program personnel must have the following background checks in order to comply with the District of Columbia’s Criminal Background Checks for the Protection of Children Act of 2004. DC Code §§ 4-1501.01 – 4-1501.11 and other OST Office requirements: • DC Child and Family Services Agency (CFSA) Child Protection Registry (CPR); • Federal Bureau of Investigation (FBI) Criminal Background Check; • Metropolitan Police Department (MPD) Criminal Background Check; and • National Sex Offender Registry. C. Any program personnel with the following felony convictions are not permitted to work or volunteer with children and youth: 1. Murder, attempted murder, manslaughter or arson; 2. Assault, battery, assault and battery, assault with a dangerous weapon, mayhem, or threats to do bodily harm; 3. Burglary; 4. Robbery; 5. Kidnapping; 6. Illegal use or possession of a firearm; 7. Sexual offenses, including indecent exposure; promoting, procuring, compelling, soliciting, or engaging in prostitution; corrupting minors (sexual relations with children); molesting; voyeurism; committing sex acts in public; incest; rape; sexual assault; sexual battery; or sexual abuse; but excluding sodomy between consenting adults; 8. Child abuse or cruelty to children; or 9. Unlawful distribution or possession of or possession with intent to distribute, a controlled substance. Condition: We sampled 60 payroll expense transactions and noted the following: • Four (4) instances in which time charged to this program was not recorded in the timesheets reviewed for the periods tested. The total of these transactions were $12,087. • Six (6) payroll transactions did not satisfy the prohibited felony background requirements as specified in the Safe Passage Safe Block grant agreement for personnel hired under this award. The total of these transactions were $16,404. • Six (6) payroll transactions from the Safe Passage Safe Block award did not show evidence of clearance by the D.C. Child and Family Services Child Protection Registry (CPR) and 2 CPRs provided were outside of the period tested. In addition, 5 CPR and First Aid training documentation were not provided. The total of these transactions were $15,585. Two (2) files did not show evidence of Metropolitan Police Department (MPD) criminal background checks as a condition for employment. Eight (8) MPD files requested were not provided. The total of these transactions were $39,102. Twenty-two (22) National Sex Offenders Registry records were not provided for persons hired under the program. This registry was managed directly by a District Agency and was not submitted to CSC. The total of these transactions were $71,408. Questioned Costs: $154,586 Context: This is a condition identified per review of CSC’s compliance with the specified requirements using a statistically valid sample. The known amount of the payroll transactions totaled $154,586. Effect: CSC is not in compliance with the stated provisions of the grant awards. Failure to properly review and support expenses can result in noncompliance with laws and regulations along with loss of funding. Cause: CSC did not appear to have adequate policies and procedures in place to ensure compliance with the required stipulations regarding background. Recommendation: We recommend that CSC ensure that personnel hired under the grant meet all the background and other checks within the stipulated time frame outlined in the grant agreement. We also recommend that CSC improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for expenses incurred and reported.