Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Activities Allowed/Unallowed and Cost Principles (Internal Control Over Compliance) Significant Deficiency ALN 20.509 Formula Grants for Rural Areas Criteria: Uniform Guidance 2 CFR, §200.313(a) requires that non-federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our review of Yankton Transit Inc.’s internal controls related to formula grants for rural areas major program, we tested disbursements for control deficiencies and transactions to support the opinion on compliance. The Point of Sale transactions (debit card purchases) had no evidence of approval of the transactions. Of the 40 transactions tested to support the opinion on compliance, 4 transactions were out of compliance. Questioned Costs: None Cause: Yankton Transit Inc.’s current policies do not address the specific procedures related to processing POS transactions prior to the transactions being processed. Effect: Disbursements are being processed without proper approval, resulting in the possibility of disallowed expenditures. Recommendation: We recommend Yankton Transit Inc. become familiar with requirements of 2 CFR, §200.313(a) and establish appropriate internal control policies and procedures and that all staff be trained on those policies and procedures, so they are familiar with the requirements. We further recommend Yankton Transit Inc. does not process payments for disbursements that do not contain necessary approval of purchases. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.
Activities Allowed/Unallowed and Cost Principles (Internal Control Over Compliance) Significant Deficiency ALN 20.509 Formula Grants for Rural Areas Criteria: Uniform Guidance 2 CFR, §200.313(a) requires that non-federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our review of Yankton Transit Inc.’s internal controls related to formula grants for rural areas major program, we tested disbursements for control deficiencies and transactions to support the opinion on compliance. The Point of Sale transactions (debit card purchases) had no evidence of approval of the transactions. Of the 40 transactions tested to support the opinion on compliance, 4 transactions were out of compliance. Questioned Costs: None Cause: Yankton Transit Inc.’s current policies do not address the specific procedures related to processing POS transactions prior to the transactions being processed. Effect: Disbursements are being processed without proper approval, resulting in the possibility of disallowed expenditures. Recommendation: We recommend Yankton Transit Inc. become familiar with requirements of 2 CFR, §200.313(a) and establish appropriate internal control policies and procedures and that all staff be trained on those policies and procedures, so they are familiar with the requirements. We further recommend Yankton Transit Inc. does not process payments for disbursements that do not contain necessary approval of purchases. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.
Activities Allowed/Unallowed and Cost Principles (Internal Control Over Compliance) Significant Deficiency ALN 20.509 Formula Grants for Rural Areas Criteria: Uniform Guidance 2 CFR, §200.313(a) requires that non-federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our review of Yankton Transit Inc.’s internal controls related to formula grants for rural areas major program, we tested disbursements for control deficiencies and transactions to support the opinion on compliance. The Point of Sale transactions (debit card purchases) had no evidence of approval of the transactions. Of the 40 transactions tested to support the opinion on compliance, 4 transactions were out of compliance. Questioned Costs: None Cause: Yankton Transit Inc.’s current policies do not address the specific procedures related to processing POS transactions prior to the transactions being processed. Effect: Disbursements are being processed without proper approval, resulting in the possibility of disallowed expenditures. Recommendation: We recommend Yankton Transit Inc. become familiar with requirements of 2 CFR, §200.313(a) and establish appropriate internal control policies and procedures and that all staff be trained on those policies and procedures, so they are familiar with the requirements. We further recommend Yankton Transit Inc. does not process payments for disbursements that do not contain necessary approval of purchases. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding Number: 2024-004 Finding Title: Internal Controls and Compliance Over Federally Funded Equipment Compliance Requirement(s): Equipment and Real Property Management Classification: Significant Deficiency Programs: Port Security Grant Program ALN #: 97.056 Pass-through entity: N/A – Direct Award Federal Agency: Department of Homeland Security Federal Award Numbers: EMW-2021-PU-00463-S01 Federal Award Year: 2021 Criteria or specific requirement (including statutory, regulatory, or other citation § 200.313 Equipment. See also § 200.439. (a) Title. Title to equipment acquired under the Federal award will vest upon acquisition in the recipient or subrecipient subject to the conditions of this section. This title must be a conditional title unless a Federal statute specifically authorizes the Federal agency to vest title in the recipient or subrecipient without further responsibility to the Federal Government (and the Federal agency elects to do so). A conditional title means a clear title is withheld by the Federal agency until conditions and requirements specified in the terms and conditions of a Federal award have been fulfilled. Title for equipment vested in a recipient or subrecipient is subject to the following conditions: (1) Use the equipment for the authorized purposes of the project during the period of performance or until the property is no longer needed for the purposes of the project. (2) While the equipment is being used for the originally authorized purpose, the recipient or subrecipient must not dispose of or encumber its title or other interests without the approval of the Federal agency or pass-through entity. (3) Use and dispose of the property in accordance with paragraphs (b), (c), and (e) of this section. (b) General. A State must use, manage and dispose of equipment acquired under a Federal award in accordance with State laws and procedures. Indian Tribes must use, manage, and dispose of equipment acquired under a Federal award in accordance with tribal laws and procedures. If such laws and procedures do not exist, Indian Tribes must follow the guidance in this section. Other recipients and subrecipients, including subrecipients of a State or Indian Tribe, must follow paragraphs (c) through (e) of this section. (c) Use. (1) The recipient or subrecipient must use equipment for the project or program for which it was acquired and for as long as needed, whether or not the project or program continues to be supported by the Federal award. The recipient or subrecipient must not encumber the equipment without prior approval of the Federal agency or pass-through entity. The Federal agency may require the submission of the applicable common forms for reporting on equipment. When no longer needed for the original project or program, the equipment may be used in other activities in the following order of priority: (i) Activities under other Federal awards from the Federal agency that funded the original program or project; then (ii) Activities under Federal awards from other Federal agencies. These activities include consolidated equipment for information technology systems. (2) During the time that equipment is used on the project or program for which it was acquired, the recipient or subrecipient must also make the equipment available for use on other programs or projects supported by the Federal Government, provided that such use will not interfere with the purpose for which it was originally acquired. First preference for other use of the equipment must be given to other programs or projects supported by the Federal agency that financed the equipment. Second preference must be given to programs or projects under Federal awards from other Federal agencies. Use for non-federally funded projects is also permissible, provided such use will not interfere with the purpose for which it was originally acquired. The recipient or subrecipient should consider charging user fees as appropriate. (3) Notwithstanding the encouragement in § 200.307 to earn program income, the recipient or subrecipient must not use equipment acquired with the Federal award to provide services for a fee that is less than a private company would charge for similar services unless specifically authorized by Federal statute. This restriction is effective as long as the Federal Government retains an interest in the equipment. (4) When acquiring replacement equipment, the recipient or subrecipient may either trade-in or sell the equipment and use the proceeds to offset the cost of the replacement equipment. (d) Management requirements. Regardless of whether equipment is acquired in part or its entirety under the Federal award, the recipient or subrecipient must manage equipment (including replacement equipment) utilizing procedures that meet the following requirements: (1) Property records must include a description of the property, a serial number or another identification number, the source of funding for the property (including the FAIN), the title holder, the acquisition date, the cost of the property, the percentage of the Federal agency contribution towards the original purchase, the location, use and condition of the property, and any disposition data including the date of disposal and sale price of the property. The recipient and subrecipient are responsible for maintaining and updating property records when there is a change in the status of the property. (2) A physical inventory of the property must be conducted, and the results must be reconciled with the property records at least once every two years. (3) A control system must be in place to ensure safeguards for preventing property loss, damage, or theft. Any loss, damage, or theft of equipment must be investigated. The recipient or subrecipient must notify the Federal agency or pass-through entity of any loss, damage, or theft of equipment that will have an impact on the program. (4) Regular maintenance procedures must be in place to ensure the property is in proper working condition. (5) If the recipient or subrecipient is authorized or required to sell the property, proper sales procedures must be in place to ensure the highest possible return. (e) Disposition. When equipment acquired under a Federal award is no longer needed for the original project, program, or for other activities currently or previously supported by a Federal agency, the recipient or subrecipient must request disposition instructions from the Federal agency or pass-through entity if required by the terms and conditions of the Federal award. Disposition of the equipment will be made as follows, in accordance with Federal agency or pass-through entity disposition instructions: (1) Equipment with a current fair market value of $10,000 or less (per unit) may be retained, sold, or otherwise disposed of with no further responsibility to the Federal agency or pass-through entity. (2) Except as provided in § 200.312(b), or if the Federal agency or pass-through entity fails to provide requested disposition instructions within 120 days, items of equipment with a current fair market value in excess of $10,000 (per-unit) may be retained or sold by the recipient or subrecipient. However, the Federal agency is entitled to an amount calculated by multiplying the percentage of the Federal agency's contribution towards the original purchase by the current market value or proceeds from the sale. If the equipment is sold, the Federal agency or pass-through entity may permit the recipient or subrecipient to retain, from the Federal share, $1,000 of the proceeds to cover expenses associated with the selling and handling of the equipment. (3) The recipient or subrecipient may transfer title to the property to the Federal Government or to an eligible third party provided that the recipient or subrecipient must be entitled to compensation for its attributable percentage of the current fair market value of the property. (4) In cases where a recipient or subrecipient fails to take appropriate disposition actions, the Federal agency or pass-through entity may direct the recipient or subrecipient to take disposition actions. Condition As part of our audit procedures, we reviewed internal controls over inventory and asset management, including physical inspection and disposition tracking of equipment. For the Fire Department, we determined that no physical inventory of federally funded equipment had been conducted during the required biennial period, and no reconciliation of equipment records to actual assets had been performed. While informal tracking logs and asset purchase records existed, they were incomplete and lacked standardized documentation of asset tag numbers, inspection dates, asset condition, and verification signatures. Moreover, there was no evidence of centralized or departmental oversight to ensure routine physical inventory and compliance with Federal property standards. In addition, we identified the Harbor department failed to properly record the disposition of a federally funded asset. The asset was still marked as “in service” within the equipment listing provided to us during the audit; however the item had in fact been disposed of during the audit period. Cause The Fire Department’s grants team oversees the compliance with required federal equipment procedures, the grants team indicated capacity issues were the main contributor towards the lack of a reconciliation or inventorying of the equipment. The Harbor Departments property related to a vehicle which was disposed of after an accident. This occurred between the departments inventory processes leading to the listing not being updated by mistake. Effect or potential effect The Departments were out of compliance with federal requirements surrounding equipment management, maintenance, and disposal. Questioned costs None Context The Harbor Department special vehicle which had an estimated book value of $0 that was involved in a collision before being disposed of. There were $0 in proceeds received related to the disposal. Identification as a repeat finding if applicable N/A Recommendation We recommend the departments enhance internal controls to ensure its property records include all the requirements under the Uniform Guidance and properly identify all property and equipment purchased with federal funds. We recommend the Fire Department implement a plan to address staffing needs and formalize procedures regarding the reconciliation, tracking, and maintenance of federally funded equipment. We recommend the Harbor Department enhance their procedures on equipment disposals. Views of responsible officials and planned corrective actions The Fire Department will ensure that all grant funds are expended in compliance with grant guidelines, including the completion of a biennial Equipment Inventory and the submission of a certification letter verifying its accuracy to the grantor every other year. Effective June 16, 2025, the Fire Department will conduct an Equipment Inventory and submit a verification letter to the grantor confirming its completion on a biennial basis. The current Equipment Inventory will be completed by the Support Services Bureau by September 30, 2025. The Fire Department will ensure the accompanying verification letter is sent to the grantor along with the updated inventory list. This biennial requirement will be integrated into the Department’s annual calendar. Following the FY2025 inventory, the next cycle will occur in FY2027 and continue in every odd-numbered fiscal year thereafter. The Harbor Department will enhance its written procedures on equipment disposals and provide training to appropriate Finance, Security, and Maintenance Division staff in FY 2025 to ensure compliance and timeliness in following equipment disposal procedures.
Finding Number: 2024-004 Finding Title: Internal Controls and Compliance Over Federally Funded Equipment Compliance Requirement(s): Equipment and Real Property Management Classification: Significant Deficiency Programs: Port Security Grant Program ALN #: 97.056 Pass-through entity: N/A – Direct Award Federal Agency: Department of Homeland Security Federal Award Numbers: EMW-2021-PU-00463-S01 Federal Award Year: 2021 Criteria or specific requirement (including statutory, regulatory, or other citation § 200.313 Equipment. See also § 200.439. (a) Title. Title to equipment acquired under the Federal award will vest upon acquisition in the recipient or subrecipient subject to the conditions of this section. This title must be a conditional title unless a Federal statute specifically authorizes the Federal agency to vest title in the recipient or subrecipient without further responsibility to the Federal Government (and the Federal agency elects to do so). A conditional title means a clear title is withheld by the Federal agency until conditions and requirements specified in the terms and conditions of a Federal award have been fulfilled. Title for equipment vested in a recipient or subrecipient is subject to the following conditions: (1) Use the equipment for the authorized purposes of the project during the period of performance or until the property is no longer needed for the purposes of the project. (2) While the equipment is being used for the originally authorized purpose, the recipient or subrecipient must not dispose of or encumber its title or other interests without the approval of the Federal agency or pass-through entity. (3) Use and dispose of the property in accordance with paragraphs (b), (c), and (e) of this section. (b) General. A State must use, manage and dispose of equipment acquired under a Federal award in accordance with State laws and procedures. Indian Tribes must use, manage, and dispose of equipment acquired under a Federal award in accordance with tribal laws and procedures. If such laws and procedures do not exist, Indian Tribes must follow the guidance in this section. Other recipients and subrecipients, including subrecipients of a State or Indian Tribe, must follow paragraphs (c) through (e) of this section. (c) Use. (1) The recipient or subrecipient must use equipment for the project or program for which it was acquired and for as long as needed, whether or not the project or program continues to be supported by the Federal award. The recipient or subrecipient must not encumber the equipment without prior approval of the Federal agency or pass-through entity. The Federal agency may require the submission of the applicable common forms for reporting on equipment. When no longer needed for the original project or program, the equipment may be used in other activities in the following order of priority: (i) Activities under other Federal awards from the Federal agency that funded the original program or project; then (ii) Activities under Federal awards from other Federal agencies. These activities include consolidated equipment for information technology systems. (2) During the time that equipment is used on the project or program for which it was acquired, the recipient or subrecipient must also make the equipment available for use on other programs or projects supported by the Federal Government, provided that such use will not interfere with the purpose for which it was originally acquired. First preference for other use of the equipment must be given to other programs or projects supported by the Federal agency that financed the equipment. Second preference must be given to programs or projects under Federal awards from other Federal agencies. Use for non-federally funded projects is also permissible, provided such use will not interfere with the purpose for which it was originally acquired. The recipient or subrecipient should consider charging user fees as appropriate. (3) Notwithstanding the encouragement in § 200.307 to earn program income, the recipient or subrecipient must not use equipment acquired with the Federal award to provide services for a fee that is less than a private company would charge for similar services unless specifically authorized by Federal statute. This restriction is effective as long as the Federal Government retains an interest in the equipment. (4) When acquiring replacement equipment, the recipient or subrecipient may either trade-in or sell the equipment and use the proceeds to offset the cost of the replacement equipment. (d) Management requirements. Regardless of whether equipment is acquired in part or its entirety under the Federal award, the recipient or subrecipient must manage equipment (including replacement equipment) utilizing procedures that meet the following requirements: (1) Property records must include a description of the property, a serial number or another identification number, the source of funding for the property (including the FAIN), the title holder, the acquisition date, the cost of the property, the percentage of the Federal agency contribution towards the original purchase, the location, use and condition of the property, and any disposition data including the date of disposal and sale price of the property. The recipient and subrecipient are responsible for maintaining and updating property records when there is a change in the status of the property. (2) A physical inventory of the property must be conducted, and the results must be reconciled with the property records at least once every two years. (3) A control system must be in place to ensure safeguards for preventing property loss, damage, or theft. Any loss, damage, or theft of equipment must be investigated. The recipient or subrecipient must notify the Federal agency or pass-through entity of any loss, damage, or theft of equipment that will have an impact on the program. (4) Regular maintenance procedures must be in place to ensure the property is in proper working condition. (5) If the recipient or subrecipient is authorized or required to sell the property, proper sales procedures must be in place to ensure the highest possible return. (e) Disposition. When equipment acquired under a Federal award is no longer needed for the original project, program, or for other activities currently or previously supported by a Federal agency, the recipient or subrecipient must request disposition instructions from the Federal agency or pass-through entity if required by the terms and conditions of the Federal award. Disposition of the equipment will be made as follows, in accordance with Federal agency or pass-through entity disposition instructions: (1) Equipment with a current fair market value of $10,000 or less (per unit) may be retained, sold, or otherwise disposed of with no further responsibility to the Federal agency or pass-through entity. (2) Except as provided in § 200.312(b), or if the Federal agency or pass-through entity fails to provide requested disposition instructions within 120 days, items of equipment with a current fair market value in excess of $10,000 (per-unit) may be retained or sold by the recipient or subrecipient. However, the Federal agency is entitled to an amount calculated by multiplying the percentage of the Federal agency's contribution towards the original purchase by the current market value or proceeds from the sale. If the equipment is sold, the Federal agency or pass-through entity may permit the recipient or subrecipient to retain, from the Federal share, $1,000 of the proceeds to cover expenses associated with the selling and handling of the equipment. (3) The recipient or subrecipient may transfer title to the property to the Federal Government or to an eligible third party provided that the recipient or subrecipient must be entitled to compensation for its attributable percentage of the current fair market value of the property. (4) In cases where a recipient or subrecipient fails to take appropriate disposition actions, the Federal agency or pass-through entity may direct the recipient or subrecipient to take disposition actions. Condition As part of our audit procedures, we reviewed internal controls over inventory and asset management, including physical inspection and disposition tracking of equipment. For the Fire Department, we determined that no physical inventory of federally funded equipment had been conducted during the required biennial period, and no reconciliation of equipment records to actual assets had been performed. While informal tracking logs and asset purchase records existed, they were incomplete and lacked standardized documentation of asset tag numbers, inspection dates, asset condition, and verification signatures. Moreover, there was no evidence of centralized or departmental oversight to ensure routine physical inventory and compliance with Federal property standards. In addition, we identified the Harbor department failed to properly record the disposition of a federally funded asset. The asset was still marked as “in service” within the equipment listing provided to us during the audit; however the item had in fact been disposed of during the audit period. Cause The Fire Department’s grants team oversees the compliance with required federal equipment procedures, the grants team indicated capacity issues were the main contributor towards the lack of a reconciliation or inventorying of the equipment. The Harbor Departments property related to a vehicle which was disposed of after an accident. This occurred between the departments inventory processes leading to the listing not being updated by mistake. Effect or potential effect The Departments were out of compliance with federal requirements surrounding equipment management, maintenance, and disposal. Questioned costs None Context The Harbor Department special vehicle which had an estimated book value of $0 that was involved in a collision before being disposed of. There were $0 in proceeds received related to the disposal. Identification as a repeat finding if applicable N/A Recommendation We recommend the departments enhance internal controls to ensure its property records include all the requirements under the Uniform Guidance and properly identify all property and equipment purchased with federal funds. We recommend the Fire Department implement a plan to address staffing needs and formalize procedures regarding the reconciliation, tracking, and maintenance of federally funded equipment. We recommend the Harbor Department enhance their procedures on equipment disposals. Views of responsible officials and planned corrective actions The Fire Department will ensure that all grant funds are expended in compliance with grant guidelines, including the completion of a biennial Equipment Inventory and the submission of a certification letter verifying its accuracy to the grantor every other year. Effective June 16, 2025, the Fire Department will conduct an Equipment Inventory and submit a verification letter to the grantor confirming its completion on a biennial basis. The current Equipment Inventory will be completed by the Support Services Bureau by September 30, 2025. The Fire Department will ensure the accompanying verification letter is sent to the grantor along with the updated inventory list. This biennial requirement will be integrated into the Department’s annual calendar. Following the FY2025 inventory, the next cycle will occur in FY2027 and continue in every odd-numbered fiscal year thereafter. The Harbor Department will enhance its written procedures on equipment disposals and provide training to appropriate Finance, Security, and Maintenance Division staff in FY 2025 to ensure compliance and timeliness in following equipment disposal procedures.
Finding 2024-002 – Activities Allowed/Unallowed, Costs Principles, and Period of Performance (Internal Controls Over Compliance) (Repeat Finding 2023-001) Material Weakness Criteria: Uniform Guidance 2 CFR, Part §200.313(a) requires that non-federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our review of the Coalition’s disbursements related to the Title V major program, we examined 68 transactions for internal controls over compliance. 7 of the 68 transactions examined did not contain sufficient evidence that a review and approval process was completed prior to payment being processed. Questioned Costs: None Cause: The Coalition does not have sufficiently established control policies and procedures to ensure proper approvals are obtained prior to the disbursement transactions being processed. Effect: Disbursements are being processed without proper approval, resulting in the possibility of disallowed expenditures. Recommendation: We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.313(a) and establishes appropriate internal control policies and procedures and that all staff be trained on those policies and procedures, so they are familiar with the requirements. We further recommend the Coalition does not process payment for disbursements that do not contain necessary approvals. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-002 – Activities Allowed/Unallowed, Costs Principles, and Period of Performance (Internal Controls Over Compliance) (Repeat Finding 2023-001) Material Weakness Criteria: Uniform Guidance 2 CFR, Part §200.313(a) requires that non-federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our review of the Coalition’s disbursements related to the Title V major program, we examined 68 transactions for internal controls over compliance. 7 of the 68 transactions examined did not contain sufficient evidence that a review and approval process was completed prior to payment being processed. Questioned Costs: None Cause: The Coalition does not have sufficiently established control policies and procedures to ensure proper approvals are obtained prior to the disbursement transactions being processed. Effect: Disbursements are being processed without proper approval, resulting in the possibility of disallowed expenditures. Recommendation: We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.313(a) and establishes appropriate internal control policies and procedures and that all staff be trained on those policies and procedures, so they are familiar with the requirements. We further recommend the Coalition does not process payment for disbursements that do not contain necessary approvals. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.
2024-002 Internal Controls over Compliance, Material Noncompliance - Equipment and Real Property Management (Material Weakness) Repeated and Modified (Prior Year Finding 2023-003) Federal Program Information: Funding Agency: Title: Federal Assistance Listing Number: Award Year and Number: Department of Housing and Urban Development Indian Housing Block Grant 14.867 2024; 55IH0402810 Criteria or specific requirements: 2 CFR Section 200.313 (d) 1 requires the Authority to maintain property records that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, acquisition date, 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. Condition: The Authority lacks a comprehensive capital asset tracking system or roll forward mechanism to accurately monitor capital assets. This includes maintaining essential information such as descriptions, serial or identifying numbers, funding sources, locations, and conditions. Cause: Procedures are not in place to ensure that a capital assets listing of buildings, real property, and equipment is regularly maintained. Effect: The Authority is not in compliance with federal requirements related to equipment and real property management. Questioned Costs: The extent of the questioned costs is unknown. Auditor's Recommendation: The Authority should develop a system to track capital assets, including description, serial or other identifying number, source of funding, location, and condition.
2024-002 Internal Controls over Compliance, Material Noncompliance - Equipment and Real Property Management (Material Weakness) Repeated and Modified (Prior Year Finding 2023-003) Federal Program Information: Funding Agency: Title: Federal Assistance Listing Number: Award Year and Number: Department of Housing and Urban Development Indian Housing Block Grant 14.867 2024; 55IH0402810 Criteria or specific requirements: 2 CFR Section 200.313 (d) 1 requires the Authority to maintain property records that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, acquisition date, 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. Condition: The Authority lacks a comprehensive capital asset tracking system or roll forward mechanism to accurately monitor capital assets. This includes maintaining essential information such as descriptions, serial or identifying numbers, funding sources, locations, and conditions. Cause: Procedures are not in place to ensure that a capital assets listing of buildings, real property, and equipment is regularly maintained. Effect: The Authority is not in compliance with federal requirements related to equipment and real property management. Questioned Costs: The extent of the questioned costs is unknown. Auditor's Recommendation: The Authority should develop a system to track capital assets, including description, serial or other identifying number, source of funding, location, and condition.
2024-002 Internal Controls over Compliance, Material Noncompliance - Equipment and Real Property Management (Material Weakness) Repeated and Modified (Prior Year Finding 2023-003) Federal Program Information: Funding Agency: Title: Federal Assistance Listing Number: Award Year and Number: Department of Housing and Urban Development Indian Housing Block Grant 14.867 2024; 55IH0402810 Criteria or specific requirements: 2 CFR Section 200.313 (d) 1 requires the Authority to maintain property records that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, acquisition date, 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. Condition: The Authority lacks a comprehensive capital asset tracking system or roll forward mechanism to accurately monitor capital assets. This includes maintaining essential information such as descriptions, serial or identifying numbers, funding sources, locations, and conditions. Cause: Procedures are not in place to ensure that a capital assets listing of buildings, real property, and equipment is regularly maintained. Effect: The Authority is not in compliance with federal requirements related to equipment and real property management. Questioned Costs: The extent of the questioned costs is unknown. Auditor's Recommendation: The Authority should develop a system to track capital assets, including description, serial or other identifying number, source of funding, location, and condition.
U.S. Department of Transportation Assistance Listing # 20.106 – Airport Improvement Program 2024-001: Equipment and Real Property Management (Significant Deficiency in Internal Control over Compliance and Immaterial Noncompliance) Criteria: Property records for equipment purchased with federal funds must be maintained at a level of detail that includes a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, 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 sales price of the property (2 CFR section 200.313(d)(1)). Condition: Our testing of the expenditures of Airport Improvement Program funds identified $192,000 of equipment purchased as part of the rehabilitation of the air traffic control tower. This equipment was recorded in the Authority’s property records. However, the property records did not contain the required data elements noted above. Effect: The Authority lacks a policy for recording federally funded equipment purchases within the property records that ensures the required data elements are captured within the property records. As a result, the Authority was not compliant with the equipment and real property management requirements of the Airport Improvement Program. Cause: The Authority’s management during the 2024 fiscal year did not appear to be aware of the equipment and real property management requirements of the Airport Improvement Program. Questioned Costs: None Context: The Authority administered two Airport Improvement Programs during the 2024 fiscal year. Total 2024 expenditures of Airport Improvement Program funds amounted to $1,710,388. Of this amount, $192,000 was for equipment that is subject to the equipment and real property management. Recommendation: We recommend the Authority review its current policies, procedures, and internal controls over the expenditure of federal awards. We recommend management establish a procedure for tracking equipment purchased with federal funding to ensure the property records contain the required data elements of the equipment and real property management compliance requirement of the Airport Improvement Program. Management’s Response: We agree with the auditor’s findings and will implement procedures to ensure our property records capture the date elements required by the equipment and real property management compliance requirement.
U.S. Department of Transportation Assistance Listing # 20.106 – Airport Improvement Program 2024-001: Equipment and Real Property Management (Significant Deficiency in Internal Control over Compliance and Immaterial Noncompliance) Criteria: Property records for equipment purchased with federal funds must be maintained at a level of detail that includes a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, 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 sales price of the property (2 CFR section 200.313(d)(1)). Condition: Our testing of the expenditures of Airport Improvement Program funds identified $192,000 of equipment purchased as part of the rehabilitation of the air traffic control tower. This equipment was recorded in the Authority’s property records. However, the property records did not contain the required data elements noted above. Effect: The Authority lacks a policy for recording federally funded equipment purchases within the property records that ensures the required data elements are captured within the property records. As a result, the Authority was not compliant with the equipment and real property management requirements of the Airport Improvement Program. Cause: The Authority’s management during the 2024 fiscal year did not appear to be aware of the equipment and real property management requirements of the Airport Improvement Program. Questioned Costs: None Context: The Authority administered two Airport Improvement Programs during the 2024 fiscal year. Total 2024 expenditures of Airport Improvement Program funds amounted to $1,710,388. Of this amount, $192,000 was for equipment that is subject to the equipment and real property management. Recommendation: We recommend the Authority review its current policies, procedures, and internal controls over the expenditure of federal awards. We recommend management establish a procedure for tracking equipment purchased with federal funding to ensure the property records contain the required data elements of the equipment and real property management compliance requirement of the Airport Improvement Program. Management’s Response: We agree with the auditor’s findings and will implement procedures to ensure our property records capture the date elements required by the equipment and real property management compliance requirement.
Equipment Management Grantor: Various Cluster: Research & Development Award Names: Various Award Numbers: Various Assistance Listing Number: Various Award Year: Various Criteria 2 CFR 200.313 (d)(1-2) indicates that a physical inventory of federal equipment must be taken and the results reconciled with property records at least once every two years. Additionally, accurate property records must be maintained which include various identifying information, such as the location, use and condition of the property and any ultimate disposition data, including the date of disposal and sale of the property. Condition In testing the Company’s conformity with the compliance requirements for equipment management, we selected 25 pieces of equipment from the detailed listings provided to physically inspect. Additionally, in order to test the completeness of the detailed listings, we selected 25 pieces of equipment from the “floor” and traced these to the detailed listings provided. Through our testing, we noted the following: • Two pieces of equipment out of the 25 selections made from the detailed listings for physical inspection were incorrectly included in the listings. o One asset was moved to another institution with the associated principal investigator. The asset was not included in the list of equipment approved for the transfer with the departure of the principal investigator. The department continued to certify the asset was in service after the transfer of the asset. The acquisition price of the asset was $6,023.36. o The second asset was acquired in 2008 and sold in 2023, at the direction of the principal investigator, with the proceeds of the sale allocated to a non-federal internal research fund. The department continued to certify the asset was in service after the disposal of the asset. Cause For the first asset that was improperly included in the detailed listing, two pieces of the same equipment were purchased together, and one of the two pieces of equipment was retained, which caused the department to inadvertently certify that both assets were still in service. Further, the asset was not included on the list of equipment approved for transfer with the principal investigator’s departure from the Company. For the second asset, the principal investigator in charge of the equipment is in the process of leaving the Company, and the department is moving or disposing of his equipment. The equipment management team was waiting until the Investigator’s space was completely cleared before updating the inventory listings. Effect The process around the transfer and/or disposal of equipment when there is a transfer of an award, or a transfer of the principal investigator is not properly reflected in the Company’s inventory records. Questioned Costs There are no questioned costs. Under the Federal Grant and Cooperative Agreement Act, 31 U.S.C. 6306, NIH permits institutions to obtain title to equipment for support of basic or applied scientific research without further obligation to the Federal government. NIH has the right to require transfer of title to equipment with an acquisition cost of $5,000 or more to the Federal government within 120 of the completion of the award. The associated award ended prior to FY24, so the title transfer period has expired. Therefore, the equipment disposal did not result in questioned costs. Recommendation We recommend that the Company provide additional training to the principal investigators and other grant personnel focusing on the policies and procedures around federal equipment management. Specifically, the training should emphasize the importance of accuracy in the disposal request forms, including federal funding. The training should also focus on the importance of timely updates to the equipment inventory listing to ensure the listing is complete and accurate. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
Equipment Management Grantor: Various Cluster: Research & Development Award Names: Various Award Numbers: Various Assistance Listing Number: Various Award Year: Various Criteria 2 CFR 200.313 (d)(1-2) indicates that a physical inventory of federal equipment must be taken and the results reconciled with property records at least once every two years. Additionally, accurate property records must be maintained which include various identifying information, such as the location, use and condition of the property and any ultimate disposition data, including the date of disposal and sale of the property. Condition In testing the Company’s conformity with the compliance requirements for equipment management, we selected 25 pieces of equipment from the detailed listings provided to physically inspect. Additionally, in order to test the completeness of the detailed listings, we selected 25 pieces of equipment from the “floor” and traced these to the detailed listings provided. Through our testing, we noted the following: • Two pieces of equipment out of the 25 selections made from the detailed listings for physical inspection were incorrectly included in the listings. o One asset was moved to another institution with the associated principal investigator. The asset was not included in the list of equipment approved for the transfer with the departure of the principal investigator. The department continued to certify the asset was in service after the transfer of the asset. The acquisition price of the asset was $6,023.36. o The second asset was acquired in 2008 and sold in 2023, at the direction of the principal investigator, with the proceeds of the sale allocated to a non-federal internal research fund. The department continued to certify the asset was in service after the disposal of the asset. Cause For the first asset that was improperly included in the detailed listing, two pieces of the same equipment were purchased together, and one of the two pieces of equipment was retained, which caused the department to inadvertently certify that both assets were still in service. Further, the asset was not included on the list of equipment approved for transfer with the principal investigator’s departure from the Company. For the second asset, the principal investigator in charge of the equipment is in the process of leaving the Company, and the department is moving or disposing of his equipment. The equipment management team was waiting until the Investigator’s space was completely cleared before updating the inventory listings. Effect The process around the transfer and/or disposal of equipment when there is a transfer of an award, or a transfer of the principal investigator is not properly reflected in the Company’s inventory records. Questioned Costs There are no questioned costs. Under the Federal Grant and Cooperative Agreement Act, 31 U.S.C. 6306, NIH permits institutions to obtain title to equipment for support of basic or applied scientific research without further obligation to the Federal government. NIH has the right to require transfer of title to equipment with an acquisition cost of $5,000 or more to the Federal government within 120 of the completion of the award. The associated award ended prior to FY24, so the title transfer period has expired. Therefore, the equipment disposal did not result in questioned costs. Recommendation We recommend that the Company provide additional training to the principal investigators and other grant personnel focusing on the policies and procedures around federal equipment management. Specifically, the training should emphasize the importance of accuracy in the disposal request forms, including federal funding. The training should also focus on the importance of timely updates to the equipment inventory listing to ensure the listing is complete and accurate. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
Finding 2024-011 – Equipment Management (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Higher Education- Institutional Aid, Assistance Listing No. 84.031 Criteria: 2 CFR Section 200.313(d)(2) establishes the requirement that a physical inventory of property must be taken and the results reconciled with the property records at least every 2 years. Condition: Documentation of a physical inventory performed college-wide was not available. Cause: The College did not perform a physical inventory of assets purchased with federal funds in the last 2 years. Effect: The College did not have appropriate documentation that a physical inventory was performed. Questioned Costs: None Recommendation: We recommend the College strengthen its policies and procedures over equipment management to ensure a physical inventory is performed every 2 years, at a minimum. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
2024-004 Internal Controls over Compliance and Compliance with Equipment and Real Property Management (Significant Deficiency) Information on the Federal Program: U.S. Department of Agriculture Assistance Listing Number: 10.606 Assistance Listing Name: Food for Progress Grant Award Number: Direct Award Number Award Period FCC-521-2016/012-00 September 29, 2016 through September 30, 2025 Criteria or Specific Requirement: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D ‐ Post Federal Award Requirements, Section 200.303 ‐ Internal Controls, requires the auditee to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with a framework such as the “Internal Control Integrated Framework”, issued by the COSO. Also, a physical inventory of property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Condition: During our testing of the equipment and real property management compliance requirements, we noted that there is no formally documented physical count of property acquired using federal funds in 2024 specific to Haiti. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS’s compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS country office personnel did not adhere to CRS’s documented policies and procedures for ensuring proper compliance with monitoring of property acquired using federal funds. Effect: Failure to conduct physical inventory of property could lead to misappropriation of assets and noncompliance with Federal regulations resulting in return of Federal awards received. Repeat Finding: No. Recommendation: We recommend that management implement policies, procedures and controls that will ensure the physical counts of property are conducted, that evidence of a count is formally documented and an authorized individual formally approves the result of the count, and the related reconciliation of property records, in order to adhere to Federal regulations related to equipment management and its related maintenance. Views of Responsible Officials: CRS management agrees with the finding and recommendations and will enhance processes surrounding property reconciliation.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-013 – Equipment Management (Noncompliance) Identification of the Federal Program: All programs Criteria: 2 CFR 200.313 requires a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition/Cause/Effect: The City has not performed a physical inventory since September 2022. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen policies and procedures to ensure a physical inventory of all city-wide departments is performed every two years. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.