2022-006: Period of Performance – Material Weakness – Originated in 2019 Federal Program Information: Funding Agency: U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: H49MC00119-22-00 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2020-2024 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 certain non-payroll expenses and lacked evidence of review for certain non-payroll expenses. Due to lack of supporting documentation and evidence of approval for payment, certain transactions could not be verified. Of the sixty (60) transactions examined, eight (8) lacked supporting documentation and twenty five (25) lacked evidence of review, and approval for payment. Effect: Management possibly did not expend funds in accordance with the approved detailed line-item 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 $980 and likely questioned costs of $5,791 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.
Formerly 2021-003: Period of Performance: Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program Condition: The organization was unable to demonstrate controls over the period of performance for six items selected for testing. 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 were six expenditures where no documentation could be provided to support that the expense was incurred during the grant period resulting in a questioned cost of $2,699 for 14.267. Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over and being unable to locate documentation. Effect: The Organization could have grant expenditures outside the grant period. Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate the period of performance. Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure the reported information is accurate. Repeat: This is a repeat finding. Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-003: Period of Performance: Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program Condition: The organization was unable to demonstrate controls over the period of performance for six items selected for testing. 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 were six expenditures where no documentation could be provided to support that the expense was incurred during the grant period resulting in a questioned cost of $2,699 for 14.267. Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over and being unable to locate documentation. Effect: The Organization could have grant expenditures outside the grant period. Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate the period of performance. Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure the reported information is accurate. Repeat: This is a repeat finding. Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-003: Period of Performance: Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program Condition: The organization was unable to demonstrate controls over the period of performance for six items selected for testing. 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 were six expenditures where no documentation could be provided to support that the expense was incurred during the grant period resulting in a questioned cost of $2,699 for 14.267. Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over and being unable to locate documentation. Effect: The Organization could have grant expenditures outside the grant period. Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate the period of performance. Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure the reported information is accurate. Repeat: This is a repeat finding. Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-003: Period of Performance: Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program Condition: The organization was unable to demonstrate controls over the period of performance for six items selected for testing. 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 were six expenditures where no documentation could be provided to support that the expense was incurred during the grant period resulting in a questioned cost of $2,699 for 14.267. Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over and being unable to locate documentation. Effect: The Organization could have grant expenditures outside the grant period. Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate the period of performance. Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure the reported information is accurate. Repeat: This is a repeat finding. Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 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 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that: For Court Appointed Special Advocates: • One of 60 transactions was partially charged in the incorrect fiscal period. • One of 60 transactions underlying supporting documentation was not retained. • 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs. • 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For the Juvenile Mentoring Program: • One of 60 transactions lacked documentation of all required reviews and approvals. • One of 60 transactions the incorrect allocation rate was utilized. • One of 60 transactions underlying supporting documentation was not retained. • 27 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. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: Below reporting threshold. 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 for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456. Identification as a Repeat Finding: Not a repeat finding. 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 procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.
Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 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 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that: For Court Appointed Special Advocates: • One of 60 transactions was partially charged in the incorrect fiscal period. • One of 60 transactions underlying supporting documentation was not retained. • 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs. • 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For the Juvenile Mentoring Program: • One of 60 transactions lacked documentation of all required reviews and approvals. • One of 60 transactions the incorrect allocation rate was utilized. • One of 60 transactions underlying supporting documentation was not retained. • 27 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. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: Below reporting threshold. 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 for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456. Identification as a Repeat Finding: Not a repeat finding. 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 procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.
Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 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 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that: For Court Appointed Special Advocates: • One of 60 transactions was partially charged in the incorrect fiscal period. • One of 60 transactions underlying supporting documentation was not retained. • 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs. • 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For the Juvenile Mentoring Program: • One of 60 transactions lacked documentation of all required reviews and approvals. • One of 60 transactions the incorrect allocation rate was utilized. • One of 60 transactions underlying supporting documentation was not retained. • 27 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. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: Below reporting threshold. 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 for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456. Identification as a Repeat Finding: Not a repeat finding. 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 procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.
Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 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 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that: For Court Appointed Special Advocates: • One of 60 transactions was partially charged in the incorrect fiscal period. • One of 60 transactions underlying supporting documentation was not retained. • 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs. • 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For the Juvenile Mentoring Program: • One of 60 transactions lacked documentation of all required reviews and approvals. • One of 60 transactions the incorrect allocation rate was utilized. • One of 60 transactions underlying supporting documentation was not retained. • 27 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. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: Below reporting threshold. 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 for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456. Identification as a Repeat Finding: Not a repeat finding. 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 procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.
Condition: For the year ended December 31, 2022, the auditee received $2,300,000 in ERA program funds but only spent $2,112,889, consisting of: $1,675,129 in direct expenses, $240,685 in furniture, fixtures, equipment, and leasehold improvements utilized for administering the program, and $197,075 in indirect cost allocations. This resulted in $187,111 unobligated funds for the ERA program that were not refunded to the grantor. Additionally, the organization spent $327,316 out of $337,290 in TANF grant funds received during the same year, which resulted in $9,974 in unobligated funds that were also not returned to the grantor. The failure to have a process to monitor and return unspent or unobligated funds highlights weaknesses in the organization’s cash and financial management processes and an apparent lack of awareness of the obligation to monitor and return unobligated funds to the grantor agency. Criteria: 2 CFR 200.308(e): Requires non‐federal entities to maintain a comparison of actual expenditures with the approved budget and explain any significant variances. 2 CFR 200.344(d): Requires unobligated balances of federal funds to be returned to the awarding agency unless specifically authorized to retain them. 2 CFR 200.303: Requires entities to establish internal controls over cash management to ensure proper use and reporting of federal funds. Cause: The organization’s failure to perform regular budget‐to‐actual comparisons and establish adequate cash management controls contributed to unspent funds remaining unreturned. Additionally, the Organization did not have an internal control process to monitor the performance period of grants which resulted in management being under the impression it could spend funds beyond the performance period in the grant contract. Effect: The lack of budget monitoring and cash management controls: 1. Increased the risk of noncompliance with federal requirements for unobligated funds. 2. Resulted in the failure to detect and return unobligated balances of $197,085 ($187,111 for the ERA program, $9,974 for the TANF program). 3. Raised concerns about the organization’s oversight and financial management capabilities. Recommendation: 1. Establish and implement procedures for preparing budget‐to‐actual comparisons for all grant programs to monitor variances regularly. 2. Develop cash management controls to ensure timely identification and return of unobligated funds, unless otherwise authorized by the grantor. 3. Strengthen financial oversight to avoid recurrence of these issues and ensure compliance with federal grant requirements. Questioned Costs: $187,111 (ERA Program). Management’s Response: Management agrees with the findings and has already initiated corrective actions. Moving forward, budget‐to‐actual comparisons will be prepared monthly, and any discrepancies will be addressed promptly. The organization will work closely with the cognizant agency to arrange for the return of any unobligated funds or, if applicable, seek authorization to retain the funds for use in other similar programs. This process will ensure proper financial management and compliance.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Finding Number: Prior Year Finding Number:N/A Compliance Requirement:Allowable Costs/Cost Principles Program:CSLRF Pass through Entity: Office of Out of School Times Grant and Youth Outcomes and NAARC - Safe Passage Safe Blocks CFDA #:21.027 Award #:SY2021-22-SPSB-008-CSC: Award Year:10/01/2021-09/30/2022 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). Condition: We sampled 40 payroll expense transactions and noted the following: ? 17 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. ? 14 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 four (4) transactions did not show evidence of Metropolitan Police Department Criminal Background Check as a condition for employment. ? CSC received four (4) separate awards funded under this CFDA number. Two of the four awards were funded under the Safe Passage Safe Blocks program and CSC failed to provide the detail expenses of $212,866 to support federal revenues received from one of the grantors. Questioned Costs:$242,698 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 $29,832 and the total of the pass-through award without detail expenses amounted to $212,866. 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 and other checks and ensuring that expenses exist prior to funds being reimbursed. 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 recommend that CSC strengthen its processes with respect to setting up and charging expenditures between various grant awards. 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.
Finding Number: Prior Year Finding Number:N/A Compliance Requirement:Allowable Costs/Cost Principles Program:CSLRF Pass through Entity: Office of Out of School Times Grant and Youth Outcomes and NAARC - Safe Passage Safe Blocks CFDA #:21.027 Award #:SY2021-22-SPSB-008-CSC: Award Year:10/01/2021-09/30/2022 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). Condition: We sampled 40 payroll expense transactions and noted the following: ? 17 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. ? 14 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 four (4) transactions did not show evidence of Metropolitan Police Department Criminal Background Check as a condition for employment. ? CSC received four (4) separate awards funded under this CFDA number. Two of the four awards were funded under the Safe Passage Safe Blocks program and CSC failed to provide the detail expenses of $212,866 to support federal revenues received from one of the grantors. Questioned Costs:$242,698 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 $29,832 and the total of the pass-through award without detail expenses amounted to $212,866. 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 and other checks and ensuring that expenses exist prior to funds being reimbursed. 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 recommend that CSC strengthen its processes with respect to setting up and charging expenditures between various grant awards. 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.
2022-002 Noncompliance with Period of Performance and Internal Controls Over Compliance ? 93.569 Criteria ? 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.308, 200.309, and 200.403(h). An entity may charge to the federal award only allowable costs incurred during the approved budget period of a federal award?s period of performance. Condition and Context ? Single audit procedures noted one expenditure that included FY2022 and FY2023 amounts. The expenditure included amounts related to October 2022, which is after the federal award period of performance, but was expensed in full to the award as of September 30, 2022. Cause ? Oversight on reviewing the cutoff of direct expenditures prior to the end of the award?s period of performance. Effect ? An expenditure below compliance materiality that was incurred after the award?s period of performance was expensed. Management posted an adjustment to remove the amounts applicable to FY2023. Questioned Costs ? None Recommendations ? Management should strengthen their processes, controls, and review over direct federal award expenditures and ensure compliance with Uniform Administrative Requirements. In addition, management should seek appropriate training for financial department staff to ensure proper cutoff of program expenditures. Views of Responsible Officials and Planned Corrective Actions ? The Association has emphasized the period of performance for all programs. Management has agreed to strengthen controls and provide training for program expenditure cutoff.
2022-002 Noncompliance with Period of Performance and Internal Controls Over Compliance ? 93.569 Criteria ? 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.308, 200.309, and 200.403(h). An entity may charge to the federal award only allowable costs incurred during the approved budget period of a federal award?s period of performance. Condition and Context ? Single audit procedures noted one expenditure that included FY2022 and FY2023 amounts. The expenditure included amounts related to October 2022, which is after the federal award period of performance, but was expensed in full to the award as of September 30, 2022. Cause ? Oversight on reviewing the cutoff of direct expenditures prior to the end of the award?s period of performance. Effect ? An expenditure below compliance materiality that was incurred after the award?s period of performance was expensed. Management posted an adjustment to remove the amounts applicable to FY2023. Questioned Costs ? None Recommendations ? Management should strengthen their processes, controls, and review over direct federal award expenditures and ensure compliance with Uniform Administrative Requirements. In addition, management should seek appropriate training for financial department staff to ensure proper cutoff of program expenditures. Views of Responsible Officials and Planned Corrective Actions ? The Association has emphasized the period of performance for all programs. Management has agreed to strengthen controls and provide training for program expenditure cutoff.
2022-002 Noncompliance with Period of Performance and Internal Controls Over Compliance ? 93.569 Criteria ? 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.308, 200.309, and 200.403(h). An entity may charge to the federal award only allowable costs incurred during the approved budget period of a federal award?s period of performance. Condition and Context ? Single audit procedures noted one expenditure that included FY2022 and FY2023 amounts. The expenditure included amounts related to October 2022, which is after the federal award period of performance, but was expensed in full to the award as of September 30, 2022. Cause ? Oversight on reviewing the cutoff of direct expenditures prior to the end of the award?s period of performance. Effect ? An expenditure below compliance materiality that was incurred after the award?s period of performance was expensed. Management posted an adjustment to remove the amounts applicable to FY2023. Questioned Costs ? None Recommendations ? Management should strengthen their processes, controls, and review over direct federal award expenditures and ensure compliance with Uniform Administrative Requirements. In addition, management should seek appropriate training for financial department staff to ensure proper cutoff of program expenditures. Views of Responsible Officials and Planned Corrective Actions ? The Association has emphasized the period of performance for all programs. Management has agreed to strengthen controls and provide training for program expenditure cutoff.
2022-002 Noncompliance with Period of Performance and Internal Controls Over Compliance ? 93.569 Criteria ? 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.308, 200.309, and 200.403(h). An entity may charge to the federal award only allowable costs incurred during the approved budget period of a federal award?s period of performance. Condition and Context ? Single audit procedures noted one expenditure that included FY2022 and FY2023 amounts. The expenditure included amounts related to October 2022, which is after the federal award period of performance, but was expensed in full to the award as of September 30, 2022. Cause ? Oversight on reviewing the cutoff of direct expenditures prior to the end of the award?s period of performance. Effect ? An expenditure below compliance materiality that was incurred after the award?s period of performance was expensed. Management posted an adjustment to remove the amounts applicable to FY2023. Questioned Costs ? None Recommendations ? Management should strengthen their processes, controls, and review over direct federal award expenditures and ensure compliance with Uniform Administrative Requirements. In addition, management should seek appropriate training for financial department staff to ensure proper cutoff of program expenditures. Views of Responsible Officials and Planned Corrective Actions ? The Association has emphasized the period of performance for all programs. Management has agreed to strengthen controls and provide training for program expenditure cutoff.
2022-002 (Significant Deficiency) ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles and Period of Performance Federal Program: AL 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: Per Uniform Guidance 2 CFR sections 200.308, 200.309 and 200.403(h), a non-federal entity may charge only allowable costs incurred during the federal award?s period of performance or grant period. Expenses incurred before the grant period can only be charged to the grant if the passthrough entity authorizes those pre-award costs. Condition: The grant period for this grant award began in March 2022. The Organization charged a portion of expenses incurred from October 2021 to February 2022 to this grant. Cause: The Organization failed to consider the grant period start date in their allocation of distribution costs to this grant. Effect: The Organization charged expenses incurred before the grant?s period of performance, which makes these expenses unallowable for this grant. Context: Most of the expenses charged to this federal award was for food purchases incurred during the grant period. Only 7% of the expenses charged were for distribution costs. The Organization followed their regular process for allocating distribution costs to grants using the costs incurred during their fiscal year of October 1, 2021 to September 2022 as their population of total expenses, failing to consider that this grant award period only began in March 2022. However, the Organization was only able to charge a small amount of this allocated distribution costs as most of the grant was reserved for food purchases. The Organization did have sufficient eligible expenses incurred during the grant period. Questioned Costs: None. Repeat Finding: No Recommendation: The Organization should review their policies and procedures for allocating expenses to grants and only allocate expenses incurred during the grant period. View of Responsible Officials: Management agrees with the recommendation and will review their procedures for allocating expenses to grants to ensure only expenses incurred during the grant period are charged to grants.
2022-002 ? 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: S351A220001 Award Period: October 4, 2021 to April 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 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).? Condition ? During our test work of 40 payroll samples, totaling $44,233.99, selected to test the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements, we noted two instances for the same employee for which the employee received compensation at a higher rate than the employee?s approved salary letter that was maintained in the personnel file. For the two samples selected, the employee received a total of $13.45 in compensation in excess of the approved amount per personnel file. Cause ? The Center is not adhering to their internal process to ensure all approved salary information was maintained in the personnel file. Effect or Potential Effect ? Without adequate internal controls in place to ensure costs are properly verified and supported, the Center could incorrectly charge expenditures to the federal program. Questioned Costs - Known questioned costs totaled $13.45 and likely questioned costs totaled $1,876. The likely questioned costs were determined by management through examination of the total salary charged to the federal program for the employee who received compensation in excess of the approved amount per personnel file. Context ? This is a condition based on testing of the Center?s compliance. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding ? N/A Recommendation - We recommend management ensure the Center strengthen their internal process to ensure that employee salary information recorded in the payroll system are approved and supported by salary documentation in the personnel file. Views of Responsible Officials ? The Center?s management agrees with the finding and will strengthen the internal control surrounding the activities allowed or unallowed and allowable costs and will ensure the adequate documentation is in place. See the Center?s corrective action for more details.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Reference Number: 2022-005 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency, Non-compliance Criteria or specific requirement: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Cause: Division did not ensure that Division 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 pass-through entity made the federal award that were authorized by the pass-through entity. Effect: Division’s will be in noncompliance with its Period of Performance compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Views of responsible officials: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. See corrective action plan.
Finding Number: Prior Year Finding Number:N/A Compliance Requirement:Allowable Costs/Cost Principles Program:CSLRF Pass through Entity: Office of Out of School Times Grant and Youth Outcomes and NAARC - Safe Passage Safe Blocks CFDA #:21.027 Award #:SY2021-22-SPSB-008-CSC: Award Year:10/01/2021-09/30/2022 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). Condition: We sampled 40 payroll expense transactions and noted the following: ? 17 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. ? 14 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 four (4) transactions did not show evidence of Metropolitan Police Department Criminal Background Check as a condition for employment. ? CSC received four (4) separate awards funded under this CFDA number. Two of the four awards were funded under the Safe Passage Safe Blocks program and CSC failed to provide the detail expenses of $212,866 to support federal revenues received from one of the grantors. Questioned Costs:$242,698 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 $29,832 and the total of the pass-through award without detail expenses amounted to $212,866. 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 and other checks and ensuring that expenses exist prior to funds being reimbursed. 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 recommend that CSC strengthen its processes with respect to setting up and charging expenditures between various grant awards. 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.
Finding Number: Prior Year Finding Number:N/A Compliance Requirement:Allowable Costs/Cost Principles Program:CSLRF Pass through Entity: Office of Out of School Times Grant and Youth Outcomes and NAARC - Safe Passage Safe Blocks CFDA #:21.027 Award #:SY2021-22-SPSB-008-CSC: Award Year:10/01/2021-09/30/2022 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). Condition: We sampled 40 payroll expense transactions and noted the following: ? 17 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. ? 14 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 four (4) transactions did not show evidence of Metropolitan Police Department Criminal Background Check as a condition for employment. ? CSC received four (4) separate awards funded under this CFDA number. Two of the four awards were funded under the Safe Passage Safe Blocks program and CSC failed to provide the detail expenses of $212,866 to support federal revenues received from one of the grantors. Questioned Costs:$242,698 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 $29,832 and the total of the pass-through award without detail expenses amounted to $212,866. 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 and other checks and ensuring that expenses exist prior to funds being reimbursed. 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 recommend that CSC strengthen its processes with respect to setting up and charging expenditures between various grant awards. 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.
2022-002 Noncompliance with Period of Performance and Internal Controls Over Compliance ? 93.569 Criteria ? 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.308, 200.309, and 200.403(h). An entity may charge to the federal award only allowable costs incurred during the approved budget period of a federal award?s period of performance. Condition and Context ? Single audit procedures noted one expenditure that included FY2022 and FY2023 amounts. The expenditure included amounts related to October 2022, which is after the federal award period of performance, but was expensed in full to the award as of September 30, 2022. Cause ? Oversight on reviewing the cutoff of direct expenditures prior to the end of the award?s period of performance. Effect ? An expenditure below compliance materiality that was incurred after the award?s period of performance was expensed. Management posted an adjustment to remove the amounts applicable to FY2023. Questioned Costs ? None Recommendations ? Management should strengthen their processes, controls, and review over direct federal award expenditures and ensure compliance with Uniform Administrative Requirements. In addition, management should seek appropriate training for financial department staff to ensure proper cutoff of program expenditures. Views of Responsible Officials and Planned Corrective Actions ? The Association has emphasized the period of performance for all programs. Management has agreed to strengthen controls and provide training for program expenditure cutoff.
2022-002 Noncompliance with Period of Performance and Internal Controls Over Compliance ? 93.569 Criteria ? 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.308, 200.309, and 200.403(h). An entity may charge to the federal award only allowable costs incurred during the approved budget period of a federal award?s period of performance. Condition and Context ? Single audit procedures noted one expenditure that included FY2022 and FY2023 amounts. The expenditure included amounts related to October 2022, which is after the federal award period of performance, but was expensed in full to the award as of September 30, 2022. Cause ? Oversight on reviewing the cutoff of direct expenditures prior to the end of the award?s period of performance. Effect ? An expenditure below compliance materiality that was incurred after the award?s period of performance was expensed. Management posted an adjustment to remove the amounts applicable to FY2023. Questioned Costs ? None Recommendations ? Management should strengthen their processes, controls, and review over direct federal award expenditures and ensure compliance with Uniform Administrative Requirements. In addition, management should seek appropriate training for financial department staff to ensure proper cutoff of program expenditures. Views of Responsible Officials and Planned Corrective Actions ? The Association has emphasized the period of performance for all programs. Management has agreed to strengthen controls and provide training for program expenditure cutoff.
2022-002 Noncompliance with Period of Performance and Internal Controls Over Compliance ? 93.569 Criteria ? 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.308, 200.309, and 200.403(h). An entity may charge to the federal award only allowable costs incurred during the approved budget period of a federal award?s period of performance. Condition and Context ? Single audit procedures noted one expenditure that included FY2022 and FY2023 amounts. The expenditure included amounts related to October 2022, which is after the federal award period of performance, but was expensed in full to the award as of September 30, 2022. Cause ? Oversight on reviewing the cutoff of direct expenditures prior to the end of the award?s period of performance. Effect ? An expenditure below compliance materiality that was incurred after the award?s period of performance was expensed. Management posted an adjustment to remove the amounts applicable to FY2023. Questioned Costs ? None Recommendations ? Management should strengthen their processes, controls, and review over direct federal award expenditures and ensure compliance with Uniform Administrative Requirements. In addition, management should seek appropriate training for financial department staff to ensure proper cutoff of program expenditures. Views of Responsible Officials and Planned Corrective Actions ? The Association has emphasized the period of performance for all programs. Management has agreed to strengthen controls and provide training for program expenditure cutoff.
2022-002 Noncompliance with Period of Performance and Internal Controls Over Compliance ? 93.569 Criteria ? 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.308, 200.309, and 200.403(h). An entity may charge to the federal award only allowable costs incurred during the approved budget period of a federal award?s period of performance. Condition and Context ? Single audit procedures noted one expenditure that included FY2022 and FY2023 amounts. The expenditure included amounts related to October 2022, which is after the federal award period of performance, but was expensed in full to the award as of September 30, 2022. Cause ? Oversight on reviewing the cutoff of direct expenditures prior to the end of the award?s period of performance. Effect ? An expenditure below compliance materiality that was incurred after the award?s period of performance was expensed. Management posted an adjustment to remove the amounts applicable to FY2023. Questioned Costs ? None Recommendations ? Management should strengthen their processes, controls, and review over direct federal award expenditures and ensure compliance with Uniform Administrative Requirements. In addition, management should seek appropriate training for financial department staff to ensure proper cutoff of program expenditures. Views of Responsible Officials and Planned Corrective Actions ? The Association has emphasized the period of performance for all programs. Management has agreed to strengthen controls and provide training for program expenditure cutoff.
2022-002 (Significant Deficiency) ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles and Period of Performance Federal Program: AL 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: Per Uniform Guidance 2 CFR sections 200.308, 200.309 and 200.403(h), a non-federal entity may charge only allowable costs incurred during the federal award?s period of performance or grant period. Expenses incurred before the grant period can only be charged to the grant if the passthrough entity authorizes those pre-award costs. Condition: The grant period for this grant award began in March 2022. The Organization charged a portion of expenses incurred from October 2021 to February 2022 to this grant. Cause: The Organization failed to consider the grant period start date in their allocation of distribution costs to this grant. Effect: The Organization charged expenses incurred before the grant?s period of performance, which makes these expenses unallowable for this grant. Context: Most of the expenses charged to this federal award was for food purchases incurred during the grant period. Only 7% of the expenses charged were for distribution costs. The Organization followed their regular process for allocating distribution costs to grants using the costs incurred during their fiscal year of October 1, 2021 to September 2022 as their population of total expenses, failing to consider that this grant award period only began in March 2022. However, the Organization was only able to charge a small amount of this allocated distribution costs as most of the grant was reserved for food purchases. The Organization did have sufficient eligible expenses incurred during the grant period. Questioned Costs: None. Repeat Finding: No Recommendation: The Organization should review their policies and procedures for allocating expenses to grants and only allocate expenses incurred during the grant period. View of Responsible Officials: Management agrees with the recommendation and will review their procedures for allocating expenses to grants to ensure only expenses incurred during the grant period are charged to grants.
2022-002 ? 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: S351A220001 Award Period: October 4, 2021 to April 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 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).? Condition ? During our test work of 40 payroll samples, totaling $44,233.99, selected to test the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements, we noted two instances for the same employee for which the employee received compensation at a higher rate than the employee?s approved salary letter that was maintained in the personnel file. For the two samples selected, the employee received a total of $13.45 in compensation in excess of the approved amount per personnel file. Cause ? The Center is not adhering to their internal process to ensure all approved salary information was maintained in the personnel file. Effect or Potential Effect ? Without adequate internal controls in place to ensure costs are properly verified and supported, the Center could incorrectly charge expenditures to the federal program. Questioned Costs - Known questioned costs totaled $13.45 and likely questioned costs totaled $1,876. The likely questioned costs were determined by management through examination of the total salary charged to the federal program for the employee who received compensation in excess of the approved amount per personnel file. Context ? This is a condition based on testing of the Center?s compliance. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding ? N/A Recommendation - We recommend management ensure the Center strengthen their internal process to ensure that employee salary information recorded in the payroll system are approved and supported by salary documentation in the personnel file. Views of Responsible Officials ? The Center?s management agrees with the finding and will strengthen the internal control surrounding the activities allowed or unallowed and allowable costs and will ensure the adequate documentation is in place. See the Center?s corrective action for more details.
Finding No. 2022-016 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D20AP00005 and D20AP00037 Area: Period of Performance Questioned Costs: $494,836 Criteria: 1. A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). 2. A non-federal entity must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award (2 CFR section 200.344(b)). Condition: Of eight expenditures tested, aggregating $593,531 of a total population of $692,970, the following were noted: 1. For four (or 50%), CNMI was unable to provide supporting documents, such as purchase orders or contracts, to support that expenditures were incurred within the period of performance. 2. For one (or 13%), CNMI was unable to provide the cancelled check to support that the expenditure was liquidated within 120 days after the end date of the period of performance. Cause: The CNMI did not provide sufficient and appropriate audit evidence to substantiate the expenditures over compliance with applicable period of performance requirement. Effect: The CNMI is in noncompliance with applicable period of performance requirements and questioned cost of $494,836 result. Recommendation: CNMI should provide timely and consistent communication with the auditors to avoid future noncompliance due to lack of supporting evidence. Having the correct documentation is crucial in determining compliance to each requirement. Views of Responsible Officials: Condition 1 - The Office of Grant Management (OGM) disagrees with this finding. Due to internal scheduling constraints and the compressed timeline required to complete the FY2022 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, OGM maintains all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Based on our records, grant award D20AP00005 remains active with a period of performance extending through September 30, 2025, while grant award D20AP00037 was closed on September 30, 2024. Both grants remained operational well beyond the originally prescribed September 30, 2022 deadline. Given the extended period of performance authorized by the awarding agency, all associated questioned costs ($494,660.00) are supported by active grant activity and should be deemed allowable. Accordingly, OGM respectfully requests that these questioned costs be removed, as they reflect legitimate expenditures incurred within the approved grant periods. Condition 2 - CIP agrees with the finding. The responsible official will report progress on corrective actions to the CNMI leadership and maintain documentation of all implemented changes. Evidence of compliance (updated policies, training records, and self-audit reports) will be provided to the auditors upon request. Refer to CNMI’s Corrective Action Plan for additional information. Auditor Response: Condition 1 - CNMI states disagreement; however, CNMI also acknowledges that documentation supporting program costs were not provided. Questioned costs are retained, as costs at the time of the audit were not supported by adequate documentation.
Finding No. 2022-035 Federal Agency: U.S. Department of Health and Human Services AL Program: 93.767 Children’s Health Insurance Program Federal Award No.: 7510515, 7520515 Area: Period of Performance Questioned Costs: $38,556 Criteria: 1. A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). 2. A non-federal entity must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award (2 CFR section 200.344(b)). Condition: CNMI was unable to provide supporting documents (i.e. invoices, contracts, etc.) to support compliance with period of performance requirements for two (or 25%) of eight expenditures tested totaling $2,105,155 of a total population of $2,163,439 . Cause: CNMI lacks monitoring control over adequate documentation and systematic filing of relevant documentations supporting program costs. Effect: CNMI is in noncompliance with applicable period of performance requirements and questioned cost of $38,556 result. Recommendation: CNMI should implement more stringent record-keeping mechanisms to ensure timely submission of audit documents upon request of the auditors used for the testing of compliance requirements. Views of Responsible Officials: The CNMI Medicaid Office disagrees with this finding. Due to internal scheduling constraints and the compressed timeline required to complete the FY2022 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, the office maintains all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Refer to CNMI’s Corrective Action Plan for additional information. Auditor Response: CNMI states disagreement; however, CNMI also acknowledges that documentation supporting program costs were not provided.