Finding Reference Number: 2025-002 Assist Listing Title: Supportive Housing for the Elderly Program Assistance Listing Number: 14.157 Federal Agency: U.S. Department of Housing and Urban Development (HUD) Federal Award Identification Number (FAIN): Federal Award Year: 2025 Pass-Through Entity: N/A Criteria: The Corporation must provide insurance coverage for real property and equipment acquired or improved with Federal funds, as required by the Federal award. Condition: For the year ended September 30, 2025, the Corporation did not maintain the required amount of property insurance coverage for certain portions of the year. Cause: The bill was not paid, which resulted in cancellation of the policy. Effect or Potential Effect: Noncompliance with HUD regulations and 2 CFR 200.310, creating risk of inadequate protection for federally funded property. Questioned Costs: $- Perspective Information: This issue was also noted in the prior audit and remains unresolved, indicating a potential systemic condition or that prior corrective actions were not fully effective. Continued monitoring and additional corrective measures are necessary to prevent recurrence. Repeat Finding: Yes Recommendation: Management should ensure that an insurance policy is in place and that coverage amounts meet HUD requirements consistently throughout the year. Views of Responsible Officials: Management agrees with the finding and has reinstated the insurance policy with required coverage amounts. Auditor's Summary of Auditee's Comments: Management reinstated the insurance policy as of December 10, 2024, and implemented controls to prevent future lapses. Response Indicator: Agree Completion Date: 12/10/2024 Response: Management has obtained an insurance policy with sufficient coverage and has increased controls around payment of premiums to ensure there are no future lapses.
Criteria - Federal regulations require that equipment and real property acquired under a federal award be properly documented in accordance with 2 CFR §§200.310–200.313 and applicable program requirements. "Equipment acquired under a federal award must be used for the authorized purposes of the project during the period of performance, or until the property is no longer needed for the project. A HSA may not dispose of, replace, or encumber title to equipment without prior ACF approval (45 CFR section 75.319; 45 CFR section 75.308(c)(1)(xi))." "Property records must be maintained for equipment acquired under a federal award that includes a description of the property, a serial number or another identification number, the source of funding for the property (including the FAIN), who holds the title, the acquisition date, and cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired the location, use, and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years." Condition and Context - The audit identified gaps in documentation and centralized tracking of equipment and real property acquired under federal awards. Certain historical additions and disposals were not fully documented in accordance with Uniform Guidance, and some current-year asset activity was not captured or reconciled in the property records. Questioned Costs - $14,410 relates to documentation and classification issues identified during the audit. Cause - Property management policies did not fully incorporate current Uniform Guidance requirements, and asset tracking relied on manual processes that were handled across multiple areas and would benefit from more consistent central oversight. Effect - Compliance risk: Noncompliance with property standards increases the risk of disallowed costs, clawbacks, or additional restrictions by the Federal agency. Reporting risk: The Schedule of Expenditures of Federal Awards (SEFA) and related disclosures may be incomplete or inaccurate if property‑related terms and conditions are not followed, affecting low‑risk auditee status evaluations under Subpart F. Recommendation - Update property management policies to mirror requirements in 2 CFR §200.313, §200.311, and §200.310, including explicit steps to (a) verify authorized use, (b) prohibit encumbrances without prior approval, (c) document and seek disposition instructions when no longer needed, and (d) maintain insurance equivalency. Provide targeted staff training and oversight. Views of responsible officials - Management concurs with the finding and views it as an opportunity to modernize property management practices. Corrective actions are underway to strengthen documentation, training, and oversight.
Federal Program 23.002 - Appalachian Area Development 14.228 - Community Development Block Grants/State's Program Award Numbers ARC-20698 ARC-20699 CDBG Subgrant: 1137-21-111-PF-01 Federal Agency U.S. Department of Housing and Urban Development (HUD) Appalachian Regional Commission (ARC) Compliance Requirement Equipment and Real Property Management- 2 CFR §200.310-316 Type of Finding Internal Control over Compliance - Material Weakness Compliance - Noncompliance Questioned Costs None Criteria Per 2 CFR §200.310-316 and the 0MB Compliance Supplement, recipients of federal awards must: Maintain detailed property records including description, serial number, acquisition date, cost, location, and condition Conduct a physical inventory at least once every two years and reconcile results Safeguard assets from loss, damage, or theft File a Notice of Federal Interest for real property acquired with federal funds Follow disposition procedures outlined in 2 CFR §200.311-313 Condition The City of Batesville did not conduct a biennial physical inventory of federally funded equipment and real property as required by 2 CFR §200.313(d)(2). Inventory records were incomplete, decentralized, and lacked key data fields such as asset condition and federal funding source. Infrastructure assets funded by CDBG and ARC grants were not classified as real property, and no Notice of Federal Interest was filed. Additionally, the City could not demonstrate that federally funded assets were safeguarded or reconciled against disposals. Cause The City lacked centralized oversight and formal policies for property management. Staff were unaware of federal requirements related to infrastructure classification and inventory procedures. No training or monitoring mechanisms were in place to ensure compliance. Effect The City is at risk of noncompliance with federal property management standards, including failure to conduct biennial inventories and file Notices of Federal Interest for real property. Although the sewer infrastructure funded by CFDA 14.228 and 23.002 is not susceptible to theft or loss due to its fixed nature, the lack of documentation and oversight represents a material weakness in internal control. No questioned costs were identified, as all expenditures were supported and the assets remain in use. Although Assistance Listing 90.201 was not selected for audit, similar deficiencies in property management were observed during preliminary review, suggesting the issue may be systemic across federal programs. Recommendation Implement a centralized inventory system with required data fields Conduct and document biennial physical inventories File Notices of Federal Interest for applicable real property Provide staff training on federal property standards Deveiop written policies for asset classification, inventory, and disposition Establish internal monitoring procedures to ensure ongoing compliance Views of Responsible Officials Management concurs with the finding. The City will implement a centralized inventory system and conduct a physical inventory by March 31, 2026. Training will be provided to relevant staff, and a formal policy will be adopted to ensure compliance with 2 CFR §200.310-316. The City will consult with HUD and ARC regarding the filing of Notices of Federal Interest for infrastructure assets. Management also acknowledges that similar issues were observed in non-audited programs and will extend corrective actions City-wide.
Federal Program Information: Funding Agency: U.S. Department of Agriculture Title: National School Lunch Program FAL Number: 10.555 & 10.553 Passthrough: N/A Award Year: 2024 Criteria: Title 2 Subtitle A Chapter II Part 200 Section 200.405 Allocable Costs (a) Allocable costs in general. A cost is allocable to a Federal award or other cost objective if the cost is assignable to that Federal award or other cost objective in accordance with the relative benefits received. This standard is met if the cost satisfies any of the following criteria: (1) Is incurred specifically for the Federal award; (2) Benefits both the Federal award and other work of the recipient or subrecipient and can be distributed in proportions that may be approximated using reasonable methods; or (3) Is necessary to the overall operation of the recipient or subrecipient and is assignable in part to the Federal award in accordance with these cost principles. (b) Allocation of indirect costs. All activities which benefit from the recipient's or subrecipient's indirect cost, including unallowable activities and donated services by the recipient or subrecipient or third parties, will receive an appropriate allocation of indirect costs. (c) Limitation on charging certain allocable costs to other Federal awards. A cost allocable to a particular Federal award may not be charged to other Federal awards (for example, to overcome fund deficiencies or to avoid restrictions imposed by Federal statutes, regulations, or the terms and conditions of the Federal awards). However, this prohibition would not preclude the recipient or subrecipient from shifting costs that are allowable under two or more Federal awards in accordance with existing Federal statutes, regulations, or the terms and conditions of the Federal awards. (d) Direct cost allocation principles. If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit However, when those proportions cannot be determined because of the interrelationship of the work involved, then, notwithstanding paragraph (c), the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Where the purchase of equipment or other capital asset is specifically authorized under a Federal award, the costs are assignable to the Federal award regardless of the use that may be made of the equipment or other capital asset involved, when no longer needed for the purpose for which it was originally required. See also §§ 200.310 through 200.316 and 200.439. Condition: During our review of national school lunch payroll, we identified the following issues: The District used school lunch funds to pay the payroll of an employee who was not working in the program. The employee worked in transportation and accounts payable. Questioned Costs: $59,074.56. This is the amount of school lunch program funds which were paid to the employee. We did not identify any other employees who were not legitimate employees of the school lunch program. Cause: The District did not ensure the funds expended were related to the national school lunch program. Effect: The District is not in compliance with Federal regulations related to internal control procedures and compliance requirements in relation to the grant and could put funding in jeopardy or require the District to reimburse the program. Auditor’s Recommendation: We recommend that all expenditures from the Food Service funds be related to food service. Ensure that only employees in food service are paid out of the national school lunch program funds. Responsible official’s view: Specific corrective action plan for the finding: This was the result of an error in changing a employee’s position from one department to another. Moving forward, the Human Resources Department will notify Payroll of any changes in position and will require TWO SIGNATURES prior to making any changes in pay coding. Timeline for completion of corrective action plan: Immediately. This process has already been put in place. Employee positions(s) responsible for meeting the timeline: Finance Director and Human Resources Director
Federal Program Information: Funding Agency: U.S. Department of Agriculture Title: National School Lunch Program FAL Number: 10.555 & 10.553 Passthrough: N/A Award Year: 2024 Criteria: Title 2 Subtitle A Chapter II Part 200 Section 200.405 Allocable Costs (a) Allocable costs in general. A cost is allocable to a Federal award or other cost objective if the cost is assignable to that Federal award or other cost objective in accordance with the relative benefits received. This standard is met if the cost satisfies any of the following criteria: (1) Is incurred specifically for the Federal award; (2) Benefits both the Federal award and other work of the recipient or subrecipient and can be distributed in proportions that may be approximated using reasonable methods; or (3) Is necessary to the overall operation of the recipient or subrecipient and is assignable in part to the Federal award in accordance with these cost principles. (b) Allocation of indirect costs. All activities which benefit from the recipient's or subrecipient's indirect cost, including unallowable activities and donated services by the recipient or subrecipient or third parties, will receive an appropriate allocation of indirect costs. (c) Limitation on charging certain allocable costs to other Federal awards. A cost allocable to a particular Federal award may not be charged to other Federal awards (for example, to overcome fund deficiencies or to avoid restrictions imposed by Federal statutes, regulations, or the terms and conditions of the Federal awards). However, this prohibition would not preclude the recipient or subrecipient from shifting costs that are allowable under two or more Federal awards in accordance with existing Federal statutes, regulations, or the terms and conditions of the Federal awards. (d) Direct cost allocation principles. If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit However, when those proportions cannot be determined because of the interrelationship of the work involved, then, notwithstanding paragraph (c), the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Where the purchase of equipment or other capital asset is specifically authorized under a Federal award, the costs are assignable to the Federal award regardless of the use that may be made of the equipment or other capital asset involved, when no longer needed for the purpose for which it was originally required. See also §§ 200.310 through 200.316 and 200.439. Condition: During our review of national school lunch payroll, we identified the following issues: The District used school lunch funds to pay the payroll of an employee who was not working in the program. The employee worked in transportation and accounts payable. Questioned Costs: $59,074.56. This is the amount of school lunch program funds which were paid to the employee. We did not identify any other employees who were not legitimate employees of the school lunch program. Cause: The District did not ensure the funds expended were related to the national school lunch program. Effect: The District is not in compliance with Federal regulations related to internal control procedures and compliance requirements in relation to the grant and could put funding in jeopardy or require the District to reimburse the program. Auditor’s Recommendation: We recommend that all expenditures from the Food Service funds be related to food service. Ensure that only employees in food service are paid out of the national school lunch program funds. Responsible official’s view: Specific corrective action plan for the finding: This was the result of an error in changing a employee’s position from one department to another. Moving forward, the Human Resources Department will notify Payroll of any changes in position and will require TWO SIGNATURES prior to making any changes in pay coding. Timeline for completion of corrective action plan: Immediately. This process has already been put in place. Employee positions(s) responsible for meeting the timeline: Finance Director and Human Resources Director
Finding 2023 – 007: Equipment and Real Property Management (Compliance; Internal Controls Over Compliance) Material Weakness Criteria: Non-federal entities that acquire, manage, or dispose of equipment and real property purchased with federal funds are required to establish and maintain effective internal controls and inventory procedures to ensure proper management, safeguarding, and accountability of such assets. According to 2 CFR § 200.310–200.314, non-federal entities must adequately safeguard all assets and assure that they are used solely for authorized purposes. Specifically, 2 CFR § 200.313(d) requires that property records be maintained for equipment, a physical inventory be taken at least once every two years and reconciled to the property records, and that adequate maintenance procedures be implemented to keep the property in good condition. Additionally, 2 CFR § 200.407, 200.439, 200.313, and 200.311 require non-federal entities to obtain prior written approval from the federal awarding agency or pass-through entity before using federal funds to purchase or lease equipment (with a per-unit cost of $10,000 or more), land, or buildings. Condition: During our review of the Organization’s internal controls over compliance related to the Title V major program, we noted that the Organization did not obtain prior written approval from the funding agency for the purchase of land and a building with Title V funds, with the purchase exceeding the $20,000 threshold included in the Title V contract. Additionally, the Organization did not have an approved budget that included these capital expenditures. The Organization also does not have an adequate system of controls established to identify, mark, record, or maintain equipment and real property purchased with federal funds, and no periodic physical inventory of such assets is being performed. Questioned Costs: None. Cause: The Organization does not have sufficiently established control policies and procedures to ensure that prior written approval is obtained for capital expenditures as required by federal regulations and the grant contract. The Organization also lacks established control policies for identifying, marking, recording, or maintaining equipment and real property, as well as for conducting periodic inventories. Effect: The Organization is not in compliance with federal requirements for prior written approval of capital expenditures and for equipment and real property management. As a result, there is an increased risk that federal funds may be used for unallowable purposes, and the Organization may be unable to distinguish federally funded property from other property or detect if such property is misplaced or stolen. Recommendation: We recommend that the Organization becomes familiar with the requirements of 2 CFR Part 200 and establishes appropriate internal control policies and procedures to ensure that prior written approval is obtained for all capital expenditures with federal funds. We further recommend that the Organization implement procedures for maintaining property records, conducting periodic physical inventories, and ensuring all staff are trained on these requirements. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.