Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Research & Development Assistance Listing Number: 93.859 Federal Award Identification Number and Year: 5P20GM109097 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: Oklahoma State University Center for Health Sciences (OSU CHS) did not properly maintain physical inventory of property purchased with federal funds. Questioned costs: None. Context: During our testing, we identified 1 out of 40 equipment items sampled that were purchased with federal funds did not have documentation of a completed physical inventory and could not be physically observed, as the equipment was reported to be misplaced. Cause: OSU CHS did not have effective controls in place to ensure that equipment purchased with federal funds was subject to a timely physical inventory and appropriately tracked, including procedures to ensure equipment could be located for observation. Effect: As a result, OSU CHS was unable to demonstrate the existence and proper safeguarding of equipment purchased with federal funds, increasing the risk that equipment may not be properly monitored, safeguarded, or used in accordance with federal requirements. Repeat Finding: No Recommendation: We recommend that OSU CHS implement and consistently perform procedures to ensure that all equipment purchased with federal funds is subject to a physical inventory at least once every two years, with results properly documented and reconciled to equipment records. We further recommend that OSU CHS strengthen controls over tracking equipment locations to ensure that federally funded equipment can be readily identified and physically located when required. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agencies: 11 – Department of Commerce, 12 – Department of Defense, 15 – Department of the Interior, 16 – Department of Justice, 43 – National Aeronautics and Space Administration, 47 – National Science Foundation, 81 – Department of Energy, 84 – Department of Education, 93 – Department of Health and Human Services Federal Program Title: R&D Cluster and Congressional Directives Assistance Listing Number: R&D and 93.493 Award Period: July 1, 2024, through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: In accordance with 2 CFR §200.313(d), non-Federal entities must maintain effective control and accountability for all equipment acquired under a Federal award. Property records must be maintained and include, at a minimum, a description of the equipment (including a serial number or other identification number), source of funding (including the Federal award identification number), who holds title, acquisition date, cost of the equipment, percentage of Federal participation in the cost, location, use and condition of the equipment, and any ultimate disposition data, including the date of disposal and sales price or the method used to determine current fair market value. Additionally, 2 CFR §200.313(d)(2) requires a physical inventory of equipment to be taken and the results reconciled with the property records at least once every two years. 2 CFR §200.313(d)(3) further requires non-Federal entities to establish adequate safeguards to prevent loss, damage, or theft of equipment. Condition/Context: During our testing of Equipment and Real Property Management, we selected a sample of 11 equipment items, consisting of 6 items from the R&D Cluster and 5 items from the Congressional Directives program. The following exceptions were noted: • For 2 of the 6 R&D equipment items, the UEC did not perform a physical inventory within the last two years. • For 1 of the 6 R&D equipment items and 1 of the 5 Congressional Directives equipment items, the UEC did not maintain property records containing the information required under Federal equipment management requirements. • For 1 of the 6 R&D equipment items, we were unable to physically inspect the equipment, as photographs or other evidence of existence were not provided by the UEC. • For 1 of the 6 R&D equipment items, while initial property records (invoice support demonstrating review and confirmation that the equipment was received) were available, we were unable to confirm that ongoing control systems were in place to safeguard the equipment after initial acquisition. Questioned Costs: $77,610. Effect: Without complete property records, timely physical inventories, and adequate safeguarding controls, the UEC is unable to demonstrate compliance with Federal equipment management requirements, increasing the risk of loss, misuse, or improper disposition of equipment purchased with Federal funds. Cause: The UEC’s internal controls over equipment tracking, inventory, and safeguarding were not designed or implemented to consistently ensure compliance with Federal equipment management requirements across Federal programs. Repeat Finding: No. Recommendation: We recommend the UEC establish and implement equipment management procedures to ensure property records are complete, physical inventories are performed at least biennially, and adequate safeguards are maintained for all equipment acquired with Federal funds. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Equipment means tangible personal property, including information technology systems, having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-Federal entity for financial statement purposes or $5,000 (2 CFR 200.1_Equipment). Title to equipment acquired by a non-Federal entity under grants and cooperative agreements vests in the non-Federal entity subject to certain obligations and conditions (2 CFR 200.313(a)). Non-Federal Entities Other than States Non-Federal entities other than States must follow 2 CFR 200.313(c) through (e) which require that: 1. Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the Federal award or, when appropriate, under other Federal awards; however, the non-Federal entity must not encumber the equipment without prior approval of the Federal awarding agency (2 CFR 200.313(c) and (e)). 2. Property records must be maintained that include 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 200.313(d)(1)). 3. A physical inventory of the property must be taken and the results reconciled with the property records at least once every 2 years (2 CFR 200.313(d)(2)). 4. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR 200.313(d)(3)). 5. Adequate maintenance procedures must be developed to keep the property in good condition (2 CFR 200.313(d)(4)). 6. If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return (2 CFR 200.313(d)(5)). 7. When original or replacement equipment acquired under a Federal award is no longer needed for a Federal program (whether the original project or program or other activities currently or previously supported by the Federal government), the non-Federal entity must request disposition instructions from the Federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the Federal awarding agency. If the Federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per-unit fair market value in excess of $5,000 may be retained or sold. The Federal awarding agency is entitled to the Federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the Federal agency’s participation in total project costs (2 CFR 200.313(e)). While testing equipment acquisitions acquired using ESSER funds, one instance was noted in which equipment purchased was not fully added to the District records. Without proper controls over equipment requirements, there is an increased risk that the District is not in compliance with applicable federal regulations. Additionally, noncompliance could result in federal funding being reduced or taken away, or other sanctions imposed by the federal grantor agency. The District should establish (or perform existing) controls to include the required clauses of 2 CFR 200.313 to ensure equipment is being properly safeguarded and tracked.
Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Equipment/Real Property Management Criteria 2 CFR sections 200.313(c) and (e) includes a requirement for the non-federal entity to not encumber the equipment without prior approval of the federal awarding agency. 2 CFR section 200.311 includes a requirement for the non-federal entity, with prior approval by the ED or passthrough entity, may also use ESF funds to purchase real property, perform construction or minor remodeling, and for improvements to land, buildings, or equipment. Condition The District did not obtain prior approval for equipment acquisition or construction projects. This condition was noted for the following expenditures: Check 241010 Dated 12/27/2024 for $104,931.00 Check 240640 Dated 11/14/2024 for $147,398.90 Check 239597 Dated 8/30/2024 for $121,240.00 Context Per discussion with the District staff and review of program expenditures, there were 22 capital asset acquisitions during the year, we tested three of them for prior state approval. All three of these purchases were made without prior state approval. Cause The District did not properly submit for prior approval for equipment acquisition or construction until after the expenditure had been incurred and in some instances there were no submissions for prior approval. Effect The District may have purchased capital items that were not allowed by the State. Questioned Costs Undeterminable. Repeat Finding See prior year finding 2024-004. Recommendation We recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements and for the requests for acquisition to be made timely and for the appropriate expenditure amount. Management’s Response See corrective action plan.
Criteria In accordance with 2 CFR 200.313(c)(1), non-Federal entities must maintain accurate equipment records for all federally acquired equipment. At a minimum, the equipment records must include: • A description of the equipment • A serial number or other identification number • The source of funding for the equipment, including the Federal Award Identification Number (FAIN) • Who holds title • The acquisition date and cost • The location, use, and condition of the equipment • Any ultimate disposition data, including date of disposal and sales price, if applicable In accordance with 2 CFR 200.313(d)(2) requires entities to verify the existence, current utilization, and continued need for federally funded equipment through physical inventories conducted at least once every two years and to reconcile those results with the equipment records. In accordance with 2 CFR 200.303, it is emphasized that entities maintain complete and accurate equipment listings to demonstrate proper safeguarding, tracking, and continued use of equipment acquired under Federal awards Furthermore, in accordance with 2 CFR 200.303(a), 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 the 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). Conditions Found We noted that the College does not maintain a complete and accurate equipment listing for federally acquired equipment. Specifically, the equipment listing did not consistently or correctly include all required data elements outlined in 2 CFR 200.313(c). Data elements that were missing from the listing included serial number, the source of funding for the equipment, including the FAIN, and the location. The data element that was incorrectly maintained on the equipment listing was acquisition date and cost as one instance was identified where the cost of acquiring an item on the equipment listing did not agree to the College’s system of record. Additionally, we noted the College does not have a process in place to reconcile the results of the bi-annual inventory count to the property record listing in order to reflect any changes or discrepancies resulting from the count. Cause The condition resulted from the absence of formally documented policies and procedures governing the maintenance and periodic review of the federally acquired equipment listing and the requirement of reconciling the federally acquired equipment to the property record listing after conducting a bi-annual physical inventory count. Also, the College has not implemented controls to ensure that required equipment information is consistently recorded, updated, and reviewed in accordance with Federal regulations. Possible Asserted Effect Failure to maintain a complete and accurate equipment listing can result in federally acquired equipment not being properly tracked, safeguarded, or used in accordance with Federal award requirements. The lack of accurate equipment records increases the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of Federal awards. Additionally, the inability to locate equipment, inaccurate equipment records and undetected loss or misuse of federally funded equipment. Moreover, the absence of formal policies could result in federal noncompliance. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be and was not a statistically valid sample. Repeat Finding The conditions found do not constitute a repeat finding from the prior year. Recommendation We recommend that the College establish and implement formal policies and procedures to ensure that a complete and accurate equipment listing for federally acquired equipment is maintained in accordance with 2 CFR 200.303 and 313. This should include ensuring that all required data elements are recorded, that the listing is periodically reviewed and updated, and that results of physical inventories are reconciled to the equipment records to support compliance with Federal award requirements. Views of Responsible Officials The College acknowledges that the federally acquired equipment listing did not include all required data elements outlined in 2 CFR 200.313(c) and did not reconcile it against the bi-annual physical inventory completed. To mitigate the risk of incomplete equipment records for federally acquired equipment, the College is formalizing policies and procedures to ensure required data elements are recorded and maintained, implementing a periodic review process to update the equipment listing, and establishing a reconciliation process to compare bi-annual physical inventory results to the property records and promptly resolve any discrepancies. These corrective actions are being implemented in fiscal year 2026.
FINDING 2025-006 Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2023-006. Condition and Context The School Corporation had not properly designed a system of internal controls to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. The School Corporation did not have any policies or procedures in place to ensure a detailed capital asset listing was completed for the audit period and that the listing contained all the required information. During the audit period, the School Corporation purchased equipment totaling $11,495,065 with COVID-19 - Education Stabilization Fund funds. However, the purchased equipment was not included on a capital asset listing or physical inventory. Due to the lack of a detailed capital asset listing, the equipment was not adequately safeguarded or maintained. The School Corporation should include the following required information in the detailed capital asset listing for each capital asset purchased with federal funds: 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 (FAIN)), 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, and use and condition of the property. A capital asset listing is to be maintained for assets purchased that exceed the School Corporation's capitalization threshold. The lack of internal controls and noncompliance were systemic issues throughout the audit period for the ESSER II and ESSER III grants. INDIANA STATE BOARD OF ACCOUNTS 26 MICHIGAN CITY AREA SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.313(d) states in part: "Management requirements. Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained 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, 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. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." Cause The School Corporation did not have policies or procedures in place to complete an inventory or maintain a fixed asset detail report. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, not all assets purchased with federal dollars were added to a capital asset listing. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 27 MICHIGAN CITY AREA SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure asset records include all the necessary information, new assets are properly added, and any discrepancies are reconciled. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Equipment and Real Property Management Federal Program and Specific Federal Award Identification CFDA Title and Number 84.031 Higher Education Institution Aid Federal Award Year June 30, 2025 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria Per Uniform Guidance § 200.313, institutions are required to conduct a physical inventory of equipment acquired with federal funds at least once every two years and reconcile the results with property records. Conditions and Contexts The University did not provide evidence that a physical inventory of federally funded equipment was performed at least once every two years. Cause The University did not have adequate procedures in place to ensure that required physical inventories were performed and documented. Questioned Costs For the purposes of this condition, I have not questioned any costs. Effect The University may not be adequately safeguarding federally funded equipment, increasing the risk of loss, theft, or misuse. Repeat Finding No. Recommendation The University should implement procedures to ensure that physical inventories of equipment are conducted at least biennially and properly documented. Inventory results should be reconciled to equipment records, and discrepancies should be investigated and resolved. Management’s Response The University acknowledges the finding regarding the absence of documented evidence that a physical inventory of federally funded equipment was performed within the required two year period. We recognize that maintaining proper inventory controls is essential to safeguarding federal property in accordance with Uniform Guidance §200.313. Corrective Actions 1. Implementation of a Biennial Inventory Schedule: The University has established a formal schedule to ensure that physical inventories of federally funded equipment are conducted at least once every two years and are documented consistently. 2. Centralized Inventory Documentation: A computerized inventory tracking system has been implemented to store all inventory records, reconciliation reports, and supporting documentation to ensure availability for audit. 3. Reconciliation Procedures: Equipment inventory results will be reconciled to the University’s fixed asset and property records, with any discrepancies documented, investigated, and resolved. 4. Staff Training and Oversight: Staff responsible for property management will receive updated training on federal inventory requirements, documentation standards, and reconciliation procedures. Supervisory review has been added to ensure ongoing compliance. The University believes these actions will strengthen internal controls over equipment management and ensure compliance with federal regulations moving forward.
2025-004 – Equipment and Real Property Management Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Rural Health Outreach and Rural Network Development Program Assistance listing numbers: 93.912 Award year: 7/1/2024 – 6/30/2025 Criteria: According to 2 CFR 200.313, property records must be maintained that include 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. Additionally, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Condition: During our audit, we noted that a complete listing of property, furniture, and equipment is not maintained in the accounting system. Additionally, SFRC did not perform a physical inventory of its property and equipment during fiscal year 2025 and there is no evidence supporting when the last physical inventory of property and equipment occurred as of June 30, 2025. Context: N/A Questioned Costs: None Cause: When the fixed asset module of the accounting system was implemented, fully depreciated items were not imported into the fixed asset module. Additionally, SFRC’s P&P Manual does not contain formal policies related to property, furniture, and equipment. Effect: The asset listing in the fixed asset module of the accounting system is not complete. Without an entity-wide physical inventory, there is an increased risk that individual items of property and equipment no longer exist, are damaged or impaired, or are being used by another program/location. Auditor’s Recommendation: SFRC should create policies and procedures over property, furniture, and equipment and add this information to its Accounting & Financial Management Policies and Procedures Manual. SFRC should also obtain the detailed asset listing from the audit and import this information into its fixed asset module so that the listing is complete going forward. Lastly, SFRC should perform a physical inventory of its property, furniture, and equipment and reconcile the result of this inventory to its fixed asset module. Management’s Response: Management reviewed existing accounting staffing structure, revised position descriptions, and have advertised to fill two of three open positions; Accounts Payable Specialist and Controller. Management feels with these revised position descriptions, more focus on accounting operations, procedures, and property and equipment management.
Finding No. 2025-044 Prior Year Finding: 2024-044 Federal Awarding Agency: U.S. Department of the Interior Impact: Material Weakness AL Number and Title: 15.605, 15.611 Fish and Wildlife Cluster (FWC) Federal Award Number: Multiple Applicable Compliance Requirement: Equipment and Real Property Management Condition: Auditors could not obtain sufficient appropriate evidence to verify compliance with FWC’s equipment and real property management requirements. Context: DFG is responsible for ensuring equipment, real property, and capital improvements, acquired with FWC funds, are used for an authorized purpose, sufficiently tracked, and appropriately disposed of in accordance with federal regulations. DFG began efforts in FY 25 to address equipment and real property management weaknesses found in the prior year audit. However, at the end of FY 25, corrective action was incomplete. In FY 25, DFG did not maintain sufficient evidence to demonstrate compliance with equipment and real property management requirements. DFG equipment and real property records did not reliably catalog the universe of equipment, real property, and capital improvements funded with FWC grant monies. Equipment records were incomplete and not trackable by funding source in the accounting system. As a result, the audit was unable to determine the extent of equipment purchased with FWC funds. Real property records had not been reconciled since 2019 and could not be matched with DFG site visit logs. The audit could not identify the FWC assets to be monitored and the extent of site visits conducted during the audit period, and whether the site visits included monitoring for authorized uses. Cause: DFG management attributed the deficiencies to a lack of department-wide procedures, staff turnover, and insufficient training. Criteria: Title 2 CFR 200.303 requires the State to establish and maintain effective internal controls over the federal award that provides reasonable assurance that the State is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. Title 2 CFR 200.311 and Title 50 CFR 80.134 requires the State to use real property for the purpose authorized in the grant for as long as it is needed for that purpose. When real property is no longer needed for the originally authorized purpose, property must be disposed of in accordance with federal requirements. Title 2 CFR 200.313 requires the State to use, manage and dispose of equipment acquired under a federal award in accordance with State laws and procedures. Such equipment must be used for the project or program for which it was acquired and for as long as needed. The State agency must maintain equipment property records, perform physical inventory of equipment, develop a control system, and perform regular maintenance of equipment. Title 50 CFR 80.133 requires the State to maintain acquired or completed capital improvements under FWC grants to ensure that each capital improvement continues to serve its authorized purpose during its useful life. Effect: The lack of department-wide procedures increased the risk that FWC funded assets were not used for authorized purposes and properly disposed of when no longer needed. Inadequate equipment tracking increased the risk of loss or theft. Further, noncompliance with federal regulations may result in the federal awarding agency imposing additional conditions or taking corrective action, including additional reporting requirements or withholding/terminating funding. Questioned Costs: Indeterminate Recommendation: DFG’s commissioner should continue efforts to ensure procedures are developed and training is implemented so that FWC funded equipment, real property, and capital improvements are fully identified and are managed in compliance with federal requirements. Views of Responsible Officials: Management agrees with this finding.
1. FINDING NUMBER: 2025 - 003 2. THIS FINDING IS: New Repeat from Prior yearX Year originally reported? 2024 3. Federal Program Name and Year:Elementary and Secondary School Emergency Relief (ESSER) - 2024 and 2025 4. Project No.: 2024-4998-HL, 2024-4998-E3, 2025-4998-C3, 2025-4998-E2 5. AL No.: 84.425D, 84.425U, 84.425W 6. Passed Through: Illinois State Board of Education 7. Federal Agency: U.S. Department of Education 8. Criteria or specific requirement (including statutory, regulatory, or other citation): Per 2 CFR 200.313(d)(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." 9. Condition: The District was unable to demonstrate that a physical inventory was performed over the past two years. This is considered a material weakness in internal control over compliance and an instance of noncompliance over equipment and real property management. This is a repeat of finding 2024-003. 10. Questioned Costs: None 11. Context: The District has contracted with an outside vendor to perform the annual inventory but that inventory is not scheduled to take place until summer 2026. 12. Effect: Failure to perform an inventory of equipment purchased by the District could result in the inability to detect a potential loss of assets and noncompliance with federal regulations regarding the proper disposal of equipment purchased with federal funding. 13. Cause: The District did not timely engage its third party contractor to complete the capital asset inventory in time for the 2025 audit. 14. Recommendation: In addition to the District ensuring that the upcoming capital asset inventory is completed timely, we recommend that the District enact procedures to ensure future inventory updates are scheduled in a timely manner. 15. Management's response: A comprehensive physical inventory and asset verification is officially scheduled for completion during the Summer of 2026. This initiative will reconcile existing records with physical counts to ensure accurate financial reporting.
2025-002. Equipment and Real Property Management United States Department of Education, passed through New York State Department of Education: Education Stabilization Fund COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U Criteria: Education Stabilization Fund (ESF) grant awards authorized under the federal Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act and American Rescue Plan Act of 2021 (ARP) may be used for equipment purchases and capital expenditures, consistent with federal regulations 2 CFR §200.313 and 2 CFR §200.439. In accordance with 2 CFR §200.313, non-federal entities receiving federal awards are required to have procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a federal award, until disposition takes place. This includes maintaining 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 Federal Award Identification Number (FAIN), and who holds title. In addition, it requires non-federal entities to track 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 acquired with federal awards must also be taken and the results reconciled with the property inventory records at least once every two years. Condition: The District did not include the capital expenditures for the “Early Childhood Educational Center (ECEC) Door Project”, “ECEC Roof Project”, “Front Vestibule Project”, and “Playground Equipment & Rubber Surfacing of Upper Play Area” that were paid with ARP ESSER 3 funds, in its current year’s capital assets inventory record. Additionally, certain items included as additions on the capital assets appraisal inventory report, such as classrooms equipment purchased with ARP ESSER 3 funds, did not match the amounts of expenditures in the District’s financial accounting application. Cause: The District did not have adequate procedures in place to identify capital-type expenditures paid with federal grant funds, which were recorded on the District’s books as purchased services, as capitalizable assets that should be added to the capital assets inventory report and tracked. Effect: Failure to include capital assets acquired with federal awards in the District’s capital assets inventory records could lead to improper or non-compliant procedures for assets inventory management and the subsequent disposal of those capital assets. Questioned Costs: None reported. Context: The District utilized federal grant awards to pay for permissible capital improvements which have been installed in instructional buildings that are leased by the District, the District recorded those expenditures as purchased services as per the pass-through entity, New York State Education Department’s guidance. The leasehold improvements incurred and acquired as of June 30, 2024 were omitted from but subsequently added to the District’s capital assets inventory reports; however, the leasehold improvements incurred and acquired during the 2024-2025 fiscal year were not included in annual capital assets inventory report. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should revise its existing procedures for compiling annual capital assets additions information to ensure equipment and capital-type expenditures purchased with federal funds are considered and evaluated for inclusion in the District’s annual capital assets inventory records. Views of Responsible Officials of Auditee: Management acknowledges the finding. The District’s Assistant Superintendent for Human Resources and Manager of Fixed Assets will review and update the existing District policy and procedures relating to the recording and tracking of capital assets purchased with federal funds.
2025-003. Special Tests and Provisions United States Department of Education, passed through New York State Department of Education: Education Stabilization Fund COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U Criteria: Education Stabilization Fund (ESF) grant awards authorized under the federal Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act and American Rescue Plan Act of 2021 (ARP) may be used for equipment purchases and capital expenditures, consistent with federal regulations 2 CFR §200.313 and 2 CFR §200.439. Subrecipients that use ESF funds for minor remodeling, renovation or construction contracts that are over $2,000 and use laborers and mechanics must meet Davis-Bacon prevailing wage compliance requirements, described in 2 CFR Part 200, Appendix XI - Compliance Supplement, Part 4, 20.001 Wage Rate Requirements Cross-Cutting Section. Condition: The District did not have formal contracts with the contractors for some of the construction projects funded with ARP ESSER 3 funds. Although the contractors indicated in their submitted proposals that their quoted price was based on prevailing wages, there was no legally-enforceable contractual language requiring the contractors and their subcontractors to comply with the federal Wage Rate Requirements clauses and DOL regulations. Cause: The District did not have procedures in place to ensure that capital construction projects have fully-executed contracts that include language requiring contractors to comply with federal Wage Rate Requirements, such as providing certified weekly payroll reports to support their invoices for payments. Effect: The lack of written contracts with Wage Rate Requirements clauses could expose the District to financial consequences if those contractors or their subcontractors are subsequently found to have violated the Wage Rate Requirements when performing their services for the District. Questioned Costs: None reported. Context: The District utilized ARP ESSER 3 funds to pay for its “Early Childhood Educational Center (ECEC) Door Project”, “ECEC Roof Project”, “Front Vestibule Project”, and “Playground Equipment & Rubber Surfacing of Upper Play Area”. The proposals submitted by contractors for the four projects stated that their quoted prices were based on prevailing wage rates, the District approved the proposals and issued purchase orders to the contractors; only one project has a fully executed agreement by the District and the contractor. However, neither the signed agreement for the one project nor the purchase orders issued for the other three projects contained requirements for the contractor to submit certified weekly payrolls as proof of compliance with the federal Wage Rate Requirements. Certified payrolls completed by the contractors and their subcontractors sometimes did not accompany the invoices submitted for payments, the District eventually requested and received all required certified payrolls from the contractors. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should review and revise its existing procedures for reviewing and approving capital construction projects to ensure that fully-executed contracts are obtained, and that such contracts contain clauses related to the compliance with the federal Wage Rate Requirements. Views of Responsible Officials of Auditee: Management acknowledges this finding. The District will review and update the existing procedures relating to capital-type construction projects.
Finding Number: 2025‐002 Repeat Finding: Yes, 2024‐002 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425U Federal Agency: U.S Department of Education Federal Award Number: S425U210038 Pass‐Through Agency: Arizona Department of Education Questioned Costs: n/a Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Equipment and Real Property Management Criteria District management is responsible for establishing and maintaining internal control over the District’s accounting records and financial reporting in order to meet financial reporting objectives of the District. CFR 200.313 requires a physical inventory, of property purchased with federal funds, must be completed and reconciled with the property records every two years. The Uniform System of Financial Records (USFR) prescribes required procedures in the areas of capital assets including an inventory at least every three years. Condition The District lacked adequate controls over capital assets purchased with federal funds. Cause District and federal policies and internal controls in place were not always operating effectively or were not always followed. Effect The District was not in compliance with CFR 200.313. Context During our review of the District’s capital assets, we noted that the District has not performed a physical inventory and reconciliation over stewardship and capital assets since fiscal year 2017. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The District should appoint an individual to ensure that a physical inventory of property purchased with federal funds is conducted and reconciled back to the property records every two years. Views of Responsible Officials See Corrective Action Plan.
Inadequate Internal Controls over Grant-Funded Equipment Maintenance and Inventory and Noncompliance with Biennial Inventory Count Requirement Name of Federal agency: U.S. Department of the Interior Name of applicable pass-through entity: State of Alaska, Department of Community and Economic Development Federal program: National Petroleum Reserve – Alaska Assistance listing number: 15.439 Federal Award Number(s): Various Federal award period: July 1, 2024 - June 30, 2025 Criteria: According to 2 CFR 200.313(d)(2), a physical inventory of the property must be taken and the results reconciled with property records at least once every two years and 2 CFR 200.313(d)(4) states that adequate maintenance procedures must be developed to keep the property in good condition. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition Found: The Borough was unable to provide sufficient and appropriate evidence, including complete documentation, to demonstrate compliance with the biennial physical inventory requirement for grant funded equipment under the Equipment and Real Property Management compliance requirements. Specifically, no documentation was available to support whether a physical inventory was conducted in FY2024, and the FY2025 inventory was incomplete. Additionally, there was not a control designed to ensure equipment maintenance was performed as scheduled. Cause: While the Borough had an established general policy regarding physical inventory counts and equipment maintenance, the policy lacked sufficient detail to ensure consistent implementation. Specifically, the policy did not clearly define roles and responsibilities for conducting inventory counts, establish procedures for performing the inventory counts and the timing of such counts, or identify the individuals responsible for reviewing and approving inventory results and maintenance logs. In addition, organizational changes during FY2024, including the separation of the Administration and Finance departments, contributed to a breakdown in the continuity of inventory management functions. Staff turnover and a lack of training for new employees further contributed to the insufficient execution of required inventory management procedures. Possible Asserted Effect: Failure to establish effective internal controls over the biennial inventory count and maintenance requirements increases the risk that grant-funded equipment may be lost, misappropriated, or not properly accounted for, which could result in questioned costs, inaccurate financial reporting, and noncompliance with federal award requirements. Questioned Costs: None Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the Borough establish internal controls to ensure biennial inventory counts for grant-funded equipment are properly conducted, documented, and formally reconciled with the property records and to ensure equipment is kept in good condition. Views of Responsible Officials: Management concurs with the finding. In response, management will continue to implement additional controls to strengthen compliance with equipment and real property management requirements, including improvements to inventory procedures, documentation practices, and oversight. The Department of Finance will work in coordination with the Department of Administration to provide training to all relevant departments on federal guidelines and compliance requirements related to assets purchased with federal grant funds. Management will continue to monitor these controls and take further corrective action, as necessary, to ensure ongoing compliance with applicable federal requirements.
Management is responsible for maintaining controls over capital assets in accordance with 2 CFR 200.313 including updating capital asset schedules for assets purchased with Federal award monies.
2025-003– Significant Deficiency in Internal Controls over Equipment and Real Property Management; Noncompliance with Equipment and Real Property Management Condition: A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR 200.313(d)(2)). Criteria: Property records must be maintained 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, 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 (2 CFR 200.313(d)(1)). Cause: Procedures within the Organization were inadequate to ensure that required elements are regularly updated on its vehicle listing, and that the physical inventory count and reconciliation is documented. Effect: Federal interest in property are lost or inadequately tracked. Recommendation: We recommend the Organization track all Federally-required elements along with its own internal data points (such as bus number and depreciation system number) in one consolidated listing. Further, we recommend that a policy be instituted whereby a physical inventory and related reconciliation is performed annually on June 30, with the results being documented, reviewed, and approved by appropriate personnel.. Views of Responsible Officials and Planned Corrective Actions: The Organization will update its property records to include all required information. Additionally, the Organization plans to document its performance of a physical inventory count and related reconciliation on an annual basis. Repeat Finding: Yes, 2024-003
2025-001: U.S. Department of Health and Human Services, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack of Required Written Policies Condition Montana Cancer Consortium (the Consortium) does not have written policies and procedures in place as required by 2 CFR § 200.302 and § 200.313. Specifically, the Consortium lacks documented policies for: • The timing of federal cash draws; • The allowability of costs charged to federal awards; and • Documentation of time-and-effort for personal services. Criteria 2 CFR § 200.302(b)(6)–(7) requires nonfederal entities to have written procedures for: (a) cash drawdowns and (b) determining cost allowability. § 200.305 requires written cash-management procedures that minimize the time between draw and disbursement. § 200.430 requires a written policy that is consistently applied to both federal and nonfederal activities for documentation of compensation for personal services. Context At the time of completion of the audit for the year ended May 31, 2025, the written policies were not in place. We noted that the policies were implemented on December 1, 2025, which was after the fiscal year under audit had ended. Cause The Consortium has not yet developed or adopted the required written policies due to limited administrative capacity and reliance on informal practices. Effect The absence of written policies increases the risk of noncompliance with federal requirements, mismanagement of federal funds, and audit findings in future periods. It may also impair the Consortium’s ability to consistently apply federal cost principles and properly safeguard assets. Recommendation We recommend that the Consortium develop and implement written policies and procedures that comply with the requirements of Uniform Guidance. Management Response See Corrective Action Plan.
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.
Finding Number: Finding 2025-006 Program Name: Head Start and Early Head Start Pass Through Agency: N/A Type of Finding: Other Matter, compliance a. Criteria or Specific Requirement: Physical Inventory Observation: Under 2 CFR 200 200.313(4)(2), a physical inventory of property must be taken at least once every two years. The results should be reconciled with the general ledger. b. Condition: The Organization has not performed a physical inventory in the last two years. c. Context: Recipients of Federal grants are required to perform physical inventory at least once every two years. d. Questioned Costs: None identified. e. Cause: The Organization has experienced turnover and, as a result, did not perform the physical inventory. f. Effect: The capital asset listing and corresponding financial statement balances may be misstated or incomplete. Without taking a physical inventory, the Organization may be overstating or understating capital assets in its financial statements. g. Repeat: Yes. h. Recommendation: The Organization should maintain its documentation of an entitywide physical inventory of its capital assets performed every two years. Once completed, the listing should be reconciled to the general ledger control totals and the control totals adjusted to the balances supported by the physical inventory results. The Organization should also implement procedures to retain adequate supporting documentation and ensure the proper recording of additions, deletions, and depreciation on a timely basis.
Finding No. 2024-001: Equipment and Real Property Management Policy U.S. Department of Housing and Urban Development, CFDA 14.231, Emergency Solutions Grant Type of Finding: Significant Deficiency in Internal Controls over Compliance Compliance Requirement: Non-compliance Criteria: Per 2 CFR 200.313 the entity must use its own documented procedures surrounding the acquisition, safekeeping, maintenance, and disposal of all equipment and real property acquired with federal awards. Condition: When testing and evaluating the Organization’s compliance with documented policy surrounding the equipment and real property management, it was determined that the Organization does not have a documented policy. Cause: Program administrative staff are not familiar with equipment and real property management requirements of Federal grants and contracts. Effect/Context: As a result, the entity could inadvertently engage in an equipment or property transaction for which the appropriate standards were not followed. Questions Costs: None Repeat Finding from Prior Year: Yes Recommendation: Coachella Valley Rescue Mission should document and implement policy and procedures to comply with the standards surrounding equipment and real property management standards. Management’s Views and Corrective Action Plan: See the accompanying Management’s Views and Corrective Action Plan, which are considered part of this report.
FINDING 2024-001 Subject: Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and COVID-19 Airports Programs - Equipment and Real Property Management Federal Agency: Department of Transportation Federal Program: Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and COVID-19 Airports Programs Assistance Listings Number: 20.106 Federal Award Number and Year (or Other Identifying Number): 3-18-0047-033-2024 Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Modified Opinion Condition and Context Detailed property records are to be maintained when equipment having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds $5,000 is purchased with federal awards. The property records should contain the equipment description (including serial number or other identification number), 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, location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. One piece of equipment was purchased with Airport Improvement Program funds totaling $216,250. However, the equipment was not included in the Authority's property records (capital asset listing), nor did the records contain all the required information listed above. In addition, the Authority did not perform a complete physical inventory within the last two years as required. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.313(d) states in part: "Management requirements. Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained 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, 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. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." Cause Internal controls were not designed to ensure compliance with equipment management requirements as the Authority was unaware of the procedures needed. Effect Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of federal funding to the Authority. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Authority's management strengthen its system of internal controls to ensure compliance with equipment management requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding No. 2024-001: Equipment and Real Property Management Policy U.S. Department of Housing and Urban Development, CFDA 14.231, Emergency Solutions Grant Type of Finding: Significant Deficiency in Internal Controls over Compliance Compliance Requirement: Non-compliance Criteria: Per 2 CFR 200.313 the entity must use its own documented procedures surrounding the acquisition, safekeeping, maintenance, and disposal of all equipment and real property acquired with federal awards. Condition: When testing and evaluating the Organization’s compliance with documented policy surrounding the equipment and real property management, it was determined that the Organization does not have a documented policy. Cause: Program administrative staff are not familiar with equipment and real property management requirements of Federal grants and contracts. Effect/Context: As a result, the entity could inadvertently engage in an equipment or property transaction for which the appropriate standards were not followed. Questions Costs: None Repeat Finding from Prior Year: Yes Recommendation: Coachella Valley Rescue Mission should document and implement policy and procedures to comply with the standards surrounding equipment and real property management standards. Management’s Views and Corrective Action Plan: See the accompanying Management’s Views and Corrective Action Plan, which are considered part of this report.
FINDING 2024-001 Subject: Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and COVID-19 Airports Programs - Equipment and Real Property Management Federal Agency: Department of Transportation Federal Program: Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and COVID-19 Airports Programs Assistance Listings Number: 20.106 Federal Award Number and Year (or Other Identifying Number): 3-18-0047-033-2024 Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Modified Opinion Condition and Context Detailed property records are to be maintained when equipment having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds $5,000 is purchased with federal awards. The property records should contain the equipment description (including serial number or other identification number), 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, location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. One piece of equipment was purchased with Airport Improvement Program funds totaling $216,250. However, the equipment was not included in the Authority's property records (capital asset listing), nor did the records contain all the required information listed above. In addition, the Authority did not perform a complete physical inventory within the last two years as required. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.313(d) states in part: "Management requirements. Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained 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, 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. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." Cause Internal controls were not designed to ensure compliance with equipment management requirements as the Authority was unaware of the procedures needed. Effect Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of federal funding to the Authority. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Authority's management strengthen its system of internal controls to ensure compliance with equipment management requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-001 Subject: Airport Improvement Program - Equipment and Real Property Management Federal Agency: Department of Transportation Federal Program: Airport Improvement Program Assistance Listings Number: 20.106 Federal Award Number and Year (or Other Identifying Number): AIP 3-18-0059-040-2023 Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 13 DELAWARE COUNTY AIRPORT AUTHORITY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The Authority had not properly designed a system of internal controls in order to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. A property record or capital asset listing is required to be maintained for all equipment purchased with the Airport Improvement Program grant award to ensure adequate safeguards are in place to prevent loss or damage of items. The Authority used federal funds to purchase a snow broom costing $300,551. The equipment was included in the capital asset listing of the Authority; however, it did not include the proper identifying information. The Authority's capital asset listing did not include the following required information: The use and condition of the property. The percentage of federal participation in the project costs for the federal award under which the property was acquired. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.313(d) states in part: "Management requirements. Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained 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, 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. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. INDIANA STATE BOARD OF ACCOUNTS 14 DELAWARE COUNTY AIRPORT AUTHORITY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." Cause The Authority was unaware of the requirements to track the percentage of federal participation in the project costs for the federal award under which the property was acquired and the use and condition of the property. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, capital assets purchased with federal dollars were not properly added to the Authority's capital asset listing. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the Authority. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the Authority establish a proper system of internal controls and develop policies and procedures to ensure capital asset records include all the necessary information. We also recommended the Authority ensure they have a proper understanding of all grant requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-001 Information on the federal program: Subject: Assistance to Firefighters Grant Program – Internal Controls Federal Agency: Department of Homeland Security Federal Program: Assistance to Firefighters Grant Program Assistance Listing Number: 97.044 Federal Award Numbers and Years (or Other Identifying Numbers): EMW-2022-FG-08560 Pass-Through Entity: N/A Compliance Requirement: Equipment and Real Property Management Audit Finding: Material Weakness Criteria: 2 CFR 200.313(d) states in part: "Management requirements. Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained 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, 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. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." Condition: An effective internal control system was not in place at the City to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management Requirements compliance requirements. Cause: The City's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system place the City at risk of noncompliance with the grant agreement and the compliance requirements. The lack of internal controls could have allowed misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the program. Questioned Costs: There were no questioned costs identified. Context: The capital asset listing provided by the City did not include any of the assets purchased with the Assistance to Firefighters Grant program funds. The fire station has a system in place to track their capital assets, however, upon review of the capital asset listing, it did not include the assets purchased with the grant noted above. Further, the capital asset listing did not include information such as the estimated useful life of the equipment nor did it include the funding source used to purchase the equipment. The amount of equipment purchases with the Assistance to Firefighters Grant funds, for the year ended December 31, 2024, was $815,546. Identification as a repeat finding, if applicable: No. Not a repeat finding. Recommendation: We recommend the City update the capital asset listing at least annually to include all equipment and real property acquisitions and review for potential capital asset dispositions. The capital asset listing should include all required information to track capital asset acquisitions purchased with federal funding. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-001 Subject: Airport Improvement Program, COVID-19 Airports Programs, and Infrastructure Investment and Jobs Act Programs - Equipment and Real Property Management Federal Agency: Department of Transportation Federal Program: Airport Improvement Program, COVID-19 Airports Programs, and Infrastructure Investment and Jobs Act Programs Assistance Listings Number: 20.106 Federal Award Numbers and Years (or Other Identifying Numbers): 3-18-0061-19-2020, 3-18-0061-24-2023, 3-18-0061-25-2023, 3-18-0061-26-2023 Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Other Matters Condition and Context Airport Improvement grant funds may be used to acquire real and personal property, supplies, and equipment. Equipment purchased with Airport Improvement funds requires management among other things to maintain property records, complete a physical inventory, safeguard against loss, and properly maintain the equipment. A property record or capital asset listing, which would include the following attributes, is to be maintained for assets purchased. • 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 (FAIN)). • 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. Although the County purchased multiple land acquisitions using the Airport Improvement Program funds, which exceeded the County's capitalization threshold, the land acquisitions were not included on an inventory listing. Additionally, the County did not complete a capital asset inventory for airport assets every two years as required. INDIANA STATE BOARD OF ACCOUNTS 14 HENRY COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.313(d) states in part: "Management requirements. Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained 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, the acquisition date, and the 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 priced of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or must be investigated. . . ." Cause A proper system of internal controls was not designed by the management of the County. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the County's management of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. The County did not add the acquisitions to the property records as they were unaware that this should be added to property records. Effect Without the proper implementation of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. INDIANA STATE BOARD OF ACCOUNTS 15 HENRY COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) As a result, not all required elements of the property record were documented for assets acquired with Airport Improvement funds. All assets were not added to the property records. Noncompliance with the provisions of federal regulations and the terms and conditions of the federal award could result in the loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure capital assets purchased with federal funds are included on a capital asset ledger and that a physical inventory is performed every two years. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-001 Subject: Community Development Block Grants/State's program and Non-Entitlement Grants in Hawaii - Equipment and Real Property Management Federal Agency: Department of Housing and Urban Development Federal Program: Community Development Block Grants/State's program and Non-Entitlement Grants in Hawaii Assistance Listings Number: 14.228 Federal Award Number and Year (or Other Identifying Number): B22DC180001 Pass-Through Entity: Indiana Office of Community and Rural Affairs Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Other Matters Condition and Context The Town had not properly designed a system of internal controls in order to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. A property record or capital asset listing is required to be maintained for all equipment purchased with federal grant awards to ensure adequate safeguards are in place to prevent loss or damage of items. The Town used federal funds to pay for renovation work on the North Lift Station Building costing $1,064,127. The building renovations were included in the capital asset listing of the Town; however, it did not include the required property identifying information. The Towns's capital asset listing did not include the following required information: • The use and condition of the property • The percentage of federal participation in the project costs for the federal award under which the property was acquired. • Source of funding for the property (including the federal award identification number [the FAIN]) • The location of the property The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 14 TOWN OF UPLAND SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.313(d) states in part: ". . . (1) Property records must be maintained 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, 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. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." Cause The Town did not have adequate internal controls in place to ensure personnel were aware of the federal requirements for assets. The Town was unaware of the requirements regarding identifying information for assets purchased with federal funds. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, assets purchased with federal dollars were not properly identified in the Town's asset listing. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the Town. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the Town establish a proper system of internal controls and develop policies and procedures to ensure asset records include all the necessary information. We also recommended the Town ensure it has a proper understanding of all grant requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Information on the Federal Program: Assistance Listing Number 81.086— Upper Midwest Inter‐Tribal EV Charging Community Network. Compliance Requirement: Equipment and Real Property Type of Finding: Noncompliance and material weakness in internal control over compliance. Criteria: 2 CFR 200.313 item (d): Property Standards. 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. Condition: For real property and equipment purchased with federal funding by Native Sun, adequate records and agreements were not kept. This included a lack of a listing as referenced above and a lack of agreement with beneficiaries of real property and equipment to ensure they remained in compliance with federal standards. Causes: The Organization was not retaining adequate records of equipment transferred to beneficiaries. Effect or Potential Effect: There could be equipment or real property purchased with federal funding that is not adequately accounted for or used outside of the bounds of the designated project use. There could also be equipment or real property unaccounted for or disposed of in a way that is not in compliance with federal standards. Large purchases of equipment including an electric bus and a bus garage lacked agreements that ensured that these items were accounted for in compliance with federal standards. Questioned Costs: None Context: The Organization did not have adequate controls in place to ensure that two of eight equipment and real property purchases tested were in compliance with federal guidelines. In addition, the organization was not able to provide an equipment list which included all required information at the beginning of the single audit process. Repeat Finding: No Recommendation: We recommend the Organization maintain a detailed listing of all real property and equipment purchased with federal funding that adheres to the criteria noted in 2 CFR Part 200. We also recommend the Organization have signed agreements dictating the treatment of real property and equipment with beneficiaries of all items that ownership is transferred from the Organization to ensure compliance. Views of Responsible Officials: Agree.
Finding 2024-002 (Significant Deficiency) Program(s): Conservation, Research, and Development Federal Agency: Department of Energy AL #: 81.086 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: Various – See SEFA Type of Compliance Finding: F) Equipment and Real Property Management Criteria Per 2 CFR section 200.313(d)(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. Condition/Context During our audit of the Organization’s fiscal year ended December 31, 2024 federal award program, we noted the Organization did not conduct the physical inventory, as required. Cause Organization management had scheduled a property inventory for 2024 (no physical inventory was planned or completed in 2023). However, due to turnover of two key personnel charged with leading this work, they have no records of the results. They are completing one in 2025. Effect Management is not in compliance with the requirements of the federal award. Questioned Costs None Is the finding a repeat finding No Recommendations We recommend that Management perform the required physical inventory, as soon as possible Views of Responsible Officials / Planned Corrective Actions Management agrees with the finding. See Corrective Action Plan on Organization’s letterhead.
Finding 2024-003 Information on the federal program: Subject: Water and Waste Disposal Systems for Rural Communities – Equipment and Real Property Management Federal Agency: U.S. Department of Agriculture Assistance Listing Number: 10.760 Federal Award Number: N/A Pass-Through Entity: N/A Compliance Requirements: Equipment and Real Property Management Audit Finding: Material Weakness, Noncompliance, Qualified Opinion Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.313(d)(1) states in part: "Property records must be maintained that include 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" Condition: An effective internal control system was not in place at the District to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. Cause: Management had not established a system of internal control that would have ensured proper procedures are followed to comply with the Equipment and Real Property Management compliance requirements. Effect: The failure to establish an effective internal control system enabled noncompliance to go undetected and the proper tracking of assets acquired with federal funds was not taking place. Noncompliance with the grant agreement and the Equipment and Real Property Management compliance requirement could have resulted in the loss of federal funds to the District. Questioned Costs: There were no questioned costs identified. Context: The District did not maintain an updated asset listing that reflects the construction in process balance related to the project funded with federal funds. There was approximately $25.0 million of disbursements from federal funds related to the project as of December 31, 2024. Identification as a repeat finding, if applicable: This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2023-003. Recommendation: We recommend that the District’s management establish controls related to the grant agreement and the Equipment and Real Property compliance requirement to ensure that assets being purchased with federal funds are added to the capital asset listing and all required information is maintained on the capital asset listing. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-004 Subject: Water and Waste Disposal System for Rural Communities - Equipment Federal Agency: Department of Agriculture Federal Program: Water and Waste Disposal System for Rural Communities Assistance Listings Number: 10.760 Federal Award Number and Year (or Other Identifying Number): 1780-12 Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 19 TOWN OF NEW MARKET SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The Town had not properly designed and implemented a system of internal controls to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. A property record or capital asset listing is required to be maintained for all equipment purchased with federal grant awards to ensure adequate safeguards are in place to prevent loss or damage of items. The Town disbursed federal funds for its Sewer Construction project and added $1,600,438 to its capital asset records in 2024 noted as "Infrastructure." None of the required information, including 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, etc., was included in the Town's property/asset records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.313(d) states: "Management requirements. Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained 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, 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. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. INDIANA STATE BOARD OF ACCOUNTS 20 TOWN OF NEW MARKET SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return." Cause The Town was unaware of the requirements regarding identifying information for assets purchased with federal funds. The Clerk-Treasurer is new to the position and is still working to implement internal controls over the Town's federal grant programs. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, assets purchased with federal dollars were not properly identified in the Town's asset listing. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the Town. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the Town establish a proper system of internal controls and develop policies and procedures to ensure asset records include all the necessary information for assets purchased with federal funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
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.
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.