Criteria: An institution must conduct a physical inventory of equipment and real property at least once every two years with results reconciled with the equipment and property records (2 CFR Section 200.313(d)(2)).Condition and Context: During our testwork over equipment and real property management, we requested support from management relating to their physical inventory of equipment and real property acquired with federal funds. We noted management was unable to produce such records, as a physical inventory of federal equipment and real property had not been conducted within the required two-year period.Cause and Effect: There was a lapse in the University's internal controls surrounding monitoring the physical inventory of equipment and real property acquired with federal funds. The University did not conduct their physical inventory of equipment and real property acquired with federal funds within the required two-year period.
Criteria: An institution must conduct a physical inventory of equipment and real property at least once every two years with results reconciled with the equipment and property records (2 CFR Section 200.313(d)(2)).Condition and Context: During our testwork over equipment and real property management, we requested support from management relating to their physical inventory of equipment and real property acquired with federal funds. We noted management was unable to produce such records, as a physical inventory of federal equipment and real property had not been conducted within the required two-year period.Cause and Effect: There was a lapse in the University's internal controls surrounding monitoring the physical inventory of equipment and real property acquired with federal funds. The University did not conduct their physical inventory of equipment and real property acquired with federal funds within the required two-year period.
Criteria: An institution must conduct a physical inventory of equipment and real property at least once every two years with results reconciled with the equipment and property records (2 CFR Section 200.313(d)(2)).Condition and Context: During our testwork over equipment and real property management, we requested support from management relating to their physical inventory of equipment and real property acquired with federal funds. We noted management was unable to produce such records, as a physical inventory of federal equipment and real property had not been conducted within the required two-year period.Cause and Effect: There was a lapse in the University's internal controls surrounding monitoring the physical inventory of equipment and real property acquired with federal funds. The University did not conduct their physical inventory of equipment and real property acquired with federal funds within the required two-year period.
Finding 2022-003: Equipment (50000)Assistance Listing No. 84.425 ? Education Stabilization Fund,Elementary and Secondary School Emergency Relief (ESSER) FundU.S. Department of EducationPassed through California Department of EducationCriteria: Consistent with 2 CFR section 200.311 (real property), section 200.313 (equipment), and section 200.439 (equipment and other capital expenditures) ESF funds may be used to purchase equipment. Capital expenditures for general and special purpose equipment purchases are subject to prior approval by ED or the pass-through entity.Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326).Condition: The District made three expenditures above the capital threshold for federal purchases but did not obtain prior approval from the California Department of Education. Furthermore, the District was unable to provide documentation that federal wage rate requirements were included in the contracts.Question Costs: $66,608Context: These were the only capital purchases made from this federal program in the year under audit.Cause: The District was unaware of the requirements to obtain prior approval from CDE and to obtain federal wage rate data.Effect: The funds spent on these purchases may be subject to review by or return to the awarding agency.Recommendation: We recommend that the District obtain prior approval from CDE and that contracts include federal wage rate requirements for all capital purchases from the Education Stabilization Fund.Views of Responsible Officials: The District will ensure it receives prior approval from CDE prior to making expenditures utilizing ESSER funds and will update its agreements to reflect the federal wage rate requirements when utilizing this funding.
2 CFR section 200.313(d) Equipment Management Requirements requires that (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 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) A physical inventory of the property must be taken, and the results reconciled with the property records at least once every two years. During our audit procedures over the compliance requirement of equipment management we noted that the physical inventory of the property and equipment has not been reconciled with the general ledger of the accounting records. We identified certain additions in the general ledger that were not included in the inventory and noted inconsistencies in the period in which the additions were recorded in the general ledger and the acquisition date per the physical inventory report. The lack of reconciliation of the physical inventory and the general ledger may cause errors in the accounting records and/or misuse of the equipment purchased with federal funds that may result in questioned costs. This situation is caused by the lack of adequate internal control procedures for reconciling and analyzing the financial transactions related to capital assets recorded throughout the year.
Finding 2022-007 Assistance Listing Number: 19.510 Program Title: U.S. Refugee Admissions Program Agency: U.S. Department of State Pass-Through Entity: United States Conference of Catholic Bishops Federal Award Identification Number: SPRMCO21CA3001, SPRMCO22CA0023 and SPRMCO21CA3291 Compliance Requirements: Equipment and Real Property Criteria: In accordance with Title 2 CFR Part 200.313(d)(1), Title 2 CFR Part 200.313(d)(2), and the U.S. Department of State Cooperative Agreement, a physical inventory and inventory report is required to be submitted 30 days prior to the expiration of the Cooperative Agreement that lists all items and purchase price of all non-expendable tangible personal property having a useful life of more than one year and having a current per unit fair market value of $5,000 or more per unit. The report must include a description, date of purchase, serial number, and the country in which the item was used. Condition: A physical inventory of equipment and real property purchased under the federal program is not being performed. An inventory report is not being submitted to the federal agency. Effect: A physical inventory and an inventory report was not submitted to the federal agency. Context: Total equipment charged to the federal program was $70,082 for the year ended June 30, 2022. Repeat Finding: Not applicable. Recommendation: We recommend Catholic Charities review current policies and procedures surrounding equipment and real property management and establish procedures related to physical inventory and retention of data required under Uniform Guidance. Views of the Responsible Officials: Catholic Charities of Central and Northern Missouri agrees and is currently reviewing policies and procedures surrounding equipment and real property management and physical inventory and data retention as required under Uniform Guidance.
Equipment/Real Property Management Federal Award Identification Assistance Listing Program Title: Formula Grants for Rural Areas Assistance Listing Program Number: 20.509 Federal Award ID Number and Year: Various Federal Agency: U.S. Department of Transportation Pass-Through Entity: Nebraska Department of Transportation 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)). 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)). Condition The Organization lacked certain required elements on its vehicle listing. The Organization failed to adequately document the performance of the required physical inventory. Repeat Finding No. 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 or Potential Effect Federal interests in property are lost or inadequately tracked. Questioned Costs No. Statistical Sample No. Context Nebraska Department of Transportation provides its subrecipients with an online portal through which, among other things, a vehicle listing is kept. The auditor obtained this vehicle listing, noting that most of the elements required by 2 CFR 200.313(d)(1) were present, however, out of the seven federally-funded vehicles on the listing: - Two were missing the FAIN (VINs *8494 and *2891). - One had a total purchase price of $63,670, whereas source documentation suggested a total purchase price of $103,475 (VIN *2891). - One was missing a purchase price. Source documentation suggested a total purchase price of $36,231 (VIN *2472). - One had an acquisition date of 9/30/2019, whereas source documentation suggested an acquisition date of 2/25/2020 (VIN *2891). Management indicates that a physical inventory is performed nightly with all vehicles, however, no documentation exists to prove that this was performed during the audit period. Recommendation We recommend the Organization establish a system of internal control consisting of policies and procedures whereby the individual maintaining vehicle listings is different from the individual updating the Nebraska Department of Transportation online portal. Additionally, 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 See Corrective Action Plan, below.
2022-006 Property Management Material Weakness CONDITION: It was noted during the audit that documentation for a detailed listing of fixed assets, a depreciation schedule and periodic inventories for fixed assets have not been maintained. CRITERIA: Federal funding agencies require maintenance of a property management system to meet statutory requirements set forth under funding contracts 2 CFR 200.313(d)(1) outline the requirements of a property management system. CAUSE: Lack of existing policies & procedures and staffing issues have contributed to this condition. EFFECT: Weak internal controls over fixed assets limits the School’s ability to properly report and safeguard its assets. Assets could be taken from the School, and it go undetected for a long period of time or never be detected at all. Weak controls also significantly increase the risk of financial misstatement occurring. Insufficient or excessive insurance coverage could result as well.
2022-006 Property Management Material Weakness CONDITION: It was noted during the audit that documentation for a detailed listing of fixed assets, a depreciation schedule and periodic inventories for fixed assets have not been maintained. CRITERIA: Federal funding agencies require maintenance of a property management system to meet statutory requirements set forth under funding contracts 2 CFR 200.313(d)(1) outline the requirements of a property management system. CAUSE: Lack of existing policies & procedures and staffing issues have contributed to this condition. EFFECT: Weak internal controls over fixed assets limits the School’s ability to properly report and safeguard its assets. Assets could be taken from the School, and it go undetected for a long period of time or never be detected at all. Weak controls also significantly increase the risk of financial misstatement occurring. Insufficient or excessive insurance coverage could result as well.
2022-006 Property Management Material Weakness CONDITION: It was noted during the audit that documentation for a detailed listing of fixed assets, a depreciation schedule and periodic inventories for fixed assets have not been maintained. CRITERIA: Federal funding agencies require maintenance of a property management system to meet statutory requirements set forth under funding contracts 2 CFR 200.313(d)(1) outline the requirements of a property management system. CAUSE: Lack of existing policies & procedures and staffing issues have contributed to this condition. EFFECT: Weak internal controls over fixed assets limits the School’s ability to properly report and safeguard its assets. Assets could be taken from the School, and it go undetected for a long period of time or never be detected at all. Weak controls also significantly increase the risk of financial misstatement occurring. Insufficient or excessive insurance coverage could result as well.
2022-006 Property Management Material Weakness CONDITION: It was noted during the audit that documentation for a detailed listing of fixed assets, a depreciation schedule and periodic inventories for fixed assets have not been maintained. CRITERIA: Federal funding agencies require maintenance of a property management system to meet statutory requirements set forth under funding contracts 2 CFR 200.313(d)(1) outline the requirements of a property management system. CAUSE: Lack of existing policies & procedures and staffing issues have contributed to this condition. EFFECT: Weak internal controls over fixed assets limits the School’s ability to properly report and safeguard its assets. Assets could be taken from the School, and it go undetected for a long period of time or never be detected at all. Weak controls also significantly increase the risk of financial misstatement occurring. Insufficient or excessive insurance coverage could result as well.
2022-006 Property Management Material Weakness CONDITION: It was noted during the audit that documentation for a detailed listing of fixed assets, a depreciation schedule and periodic inventories for fixed assets have not been maintained. CRITERIA: Federal funding agencies require maintenance of a property management system to meet statutory requirements set forth under funding contracts 2 CFR 200.313(d)(1) outline the requirements of a property management system. CAUSE: Lack of existing policies & procedures and staffing issues have contributed to this condition. EFFECT: Weak internal controls over fixed assets limits the School’s ability to properly report and safeguard its assets. Assets could be taken from the School, and it go undetected for a long period of time or never be detected at all. Weak controls also significantly increase the risk of financial misstatement occurring. Insufficient or excessive insurance coverage could result as well.
2022-006 Property Management Material Weakness CONDITION: It was noted during the audit that documentation for a detailed listing of fixed assets, a depreciation schedule and periodic inventories for fixed assets have not been maintained. CRITERIA: Federal funding agencies require maintenance of a property management system to meet statutory requirements set forth under funding contracts 2 CFR 200.313(d)(1) outline the requirements of a property management system. CAUSE: Lack of existing policies & procedures and staffing issues have contributed to this condition. EFFECT: Weak internal controls over fixed assets limits the School’s ability to properly report and safeguard its assets. Assets could be taken from the School, and it go undetected for a long period of time or never be detected at all. Weak controls also significantly increase the risk of financial misstatement occurring. Insufficient or excessive insurance coverage could result as well.
2022-006 Property Management Material Weakness CONDITION: It was noted during the audit that documentation for a detailed listing of fixed assets, a depreciation schedule and periodic inventories for fixed assets have not been maintained. CRITERIA: Federal funding agencies require maintenance of a property management system to meet statutory requirements set forth under funding contracts 2 CFR 200.313(d)(1) outline the requirements of a property management system. CAUSE: Lack of existing policies & procedures and staffing issues have contributed to this condition. EFFECT: Weak internal controls over fixed assets limits the School’s ability to properly report and safeguard its assets. Assets could be taken from the School, and it go undetected for a long period of time or never be detected at all. Weak controls also significantly increase the risk of financial misstatement occurring. Insufficient or excessive insurance coverage could result as well.
2022-006 Property Management Material Weakness CONDITION: It was noted during the audit that documentation for a detailed listing of fixed assets, a depreciation schedule and periodic inventories for fixed assets have not been maintained. CRITERIA: Federal funding agencies require maintenance of a property management system to meet statutory requirements set forth under funding contracts 2 CFR 200.313(d)(1) outline the requirements of a property management system. CAUSE: Lack of existing policies & procedures and staffing issues have contributed to this condition. EFFECT: Weak internal controls over fixed assets limits the School’s ability to properly report and safeguard its assets. Assets could be taken from the School, and it go undetected for a long period of time or never be detected at all. Weak controls also significantly increase the risk of financial misstatement occurring. Insufficient or excessive insurance coverage could result as well.
2022-006 Property Management Material Weakness CONDITION: It was noted during the audit that documentation for a detailed listing of fixed assets, a depreciation schedule and periodic inventories for fixed assets have not been maintained. CRITERIA: Federal funding agencies require maintenance of a property management system to meet statutory requirements set forth under funding contracts 2 CFR 200.313(d)(1) outline the requirements of a property management system. CAUSE: Lack of existing policies & procedures and staffing issues have contributed to this condition. EFFECT: Weak internal controls over fixed assets limits the School’s ability to properly report and safeguard its assets. Assets could be taken from the School, and it go undetected for a long period of time or never be detected at all. Weak controls also significantly increase the risk of financial misstatement occurring. Insufficient or excessive insurance coverage could result as well.
2022-006 Property Management Material Weakness CONDITION: It was noted during the audit that documentation for a detailed listing of fixed assets, a depreciation schedule and periodic inventories for fixed assets have not been maintained. CRITERIA: Federal funding agencies require maintenance of a property management system to meet statutory requirements set forth under funding contracts 2 CFR 200.313(d)(1) outline the requirements of a property management system. CAUSE: Lack of existing policies & procedures and staffing issues have contributed to this condition. EFFECT: Weak internal controls over fixed assets limits the School’s ability to properly report and safeguard its assets. Assets could be taken from the School, and it go undetected for a long period of time or never be detected at all. Weak controls also significantly increase the risk of financial misstatement occurring. Insufficient or excessive insurance coverage could result as well.
Finding Reference Number: SA 2022-006 Equipment Management AL Number: 14.218 Assistance Listing Title: CDBG - Entitlement Grants Cluster – Community Development Block Grants/Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-14-MC-06-0037, B-15-MC-06-0037, B-16-MC-06-0037, B-17-MC-06-0037, B-18-MC-06-0037, B-19-MC-06-0037, B-20-MC-06-0037, B-20-MW-06-0037, B-21-MC-06-0037 Criteria: 2 CFR 200.313(d)(1) require that 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. In addition, 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 section 200.313(d)(2)). Condition: During fiscal year 2022, the City purchased equipment in the amount of $97,933, which is reflected in the City’s capital asset records. However, those records do not include an indication that the funding source was a federal grant. The City did not yet perform the physical inventory of the federally funded property, because the purchase occurred during fiscal year 2022. Effect: The City is not in compliance with the property management provisions of 2 CFR 200.313(d)(1). Cause: We understand City staff was not aware of the property records requirement to include the federal funding source. We also understand the capital assets the system has the capability to include such a designation, but it has not been utilized to date. Recommendation: The City should develop procedures to ensure that equipment and other capital assets purchased in whole or in part with federal funds include an identification of the federal funding in compliance with the provisions of 2 CFR 200.313(d)(1). In addition, the City should ensure that procedures are in place meet the physical inventory requirements of 2 CFR section 200.313(d)(2). View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
Finding Reference Number: SA 2022-006 Equipment Management AL Number: 14.218 Assistance Listing Title: CDBG - Entitlement Grants Cluster – Community Development Block Grants/Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-14-MC-06-0037, B-15-MC-06-0037, B-16-MC-06-0037, B-17-MC-06-0037, B-18-MC-06-0037, B-19-MC-06-0037, B-20-MC-06-0037, B-20-MW-06-0037, B-21-MC-06-0037 Criteria: 2 CFR 200.313(d)(1) require that 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. In addition, 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 section 200.313(d)(2)). Condition: During fiscal year 2022, the City purchased equipment in the amount of $97,933, which is reflected in the City’s capital asset records. However, those records do not include an indication that the funding source was a federal grant. The City did not yet perform the physical inventory of the federally funded property, because the purchase occurred during fiscal year 2022. Effect: The City is not in compliance with the property management provisions of 2 CFR 200.313(d)(1). Cause: We understand City staff was not aware of the property records requirement to include the federal funding source. We also understand the capital assets the system has the capability to include such a designation, but it has not been utilized to date. Recommendation: The City should develop procedures to ensure that equipment and other capital assets purchased in whole or in part with federal funds include an identification of the federal funding in compliance with the provisions of 2 CFR 200.313(d)(1). In addition, the City should ensure that procedures are in place meet the physical inventory requirements of 2 CFR section 200.313(d)(2). View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
Federal Agency: Department of the Interior Federal Programs: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Numbers: 15.027 Federal Award Identification Number and Year: A19AP00118-09 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters Criteria: In accordance with 2 CFR 200.303, the College must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the College is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, 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 section 200.313(d)(1)). Further 200.313(d)(2) states that the property records must be reconciled with a physical inventory count at least once every two years. Condition: The College did not have documentation of physical inventory of the equipment purchased with Federal Funds. The College did not adequately track equipment funded with federal awards and their respective disposals. Further the College did not maintain the required information as part of their property and equipment records. Questioned Costs: None Context: During our testing of property and equipment purchases it was noted the property records for the equipment purchased did not contain the required information for all 11 equipment purchases we selected for testing. In addition, there was no documentation that showed a physical inventory was taken over this equipment at least every two years. Cause: The College did not have an effective control in place to ensure that the required information for equipment purchased with federal funds was maintained and that a physical inventory count was completed every two years. Effect: The College did not meet equipment property record requirements for equipment purchased with federal funds. Repeat Finding: Yes, see Finding 2021-004. Recommendation: We recommend the College implement policies and procedures to ensure all property and equipment purchased with federal funds includes such information in the property records to comply with the requirement, and physical inventory be taken at least every two years. Views of Responsible Officials: Management agrees with the finding and has prepared a plan to correct the finding.
Criteria or specific requirement: Per ?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 (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. Per the Organization's additions to Property and Equipment Policy, expenditures for tangible assets used actively in business operations with a cost exceeding $5,000 and with a useful life exceeding two years should be capitalized. Also per ?200.313, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Condition: We noted the Organization is not in compliance with requirements related to the Equipment/Real Property Management of grants. Questioned costs: None. Context: During our testing, we noted the following exceptions: ? 1 out of 2 equipment samples totaling $13,306 was not capitalized and therefore not included in the either the departments fixed asset software or year end Property and Equipment financial balance. This asset was originally purchased in fiscal year 2021. As such, the auditor could not trace the equipment to a listing and properly identify the equipment through physical inspection. ? The organization did not complete the required 2 year physical inventory of equipment for 1 out of 1 federally purchased equipment. The equipment was originally purchased in June 2020. ? The Organization was not aware of the Equipment/Real Property Management CFR Requirements and lacks a process to ensure the Organization is in compliance with Equipment/Real Property Management CFR requirements. Cause: Management oversight; lack of effective internal controls addressing the purchase of equipment with Federal Funds. Effect: The auditor noted instances of noncompliance. Noncompliance can result in delayed reimbursement of eligible Federal expenditures or potential loss of Federal funding. Repeat Finding: Yes ? 2021-001 Recommendation: We recommend that the Organization create effective internal controls and procedures over the purchase of Federally Funded Equipment and Real Property and a tracking methodology to properly identify equipment purchased with federal funds that allows for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants. Views of responsible officials: The Organization did have two purchases in FY21 that were expensed versus being capitalized. The Organization failed to follow the capital purchasing policy. The Organization has educated responsible parties of the capital purchasing policy to avoid future occurrences. The Organization has updated processes in fiscal year 2023 to ensure the purchasing policy is followed. The executive director of the program will conduct an annual physical inventory of federal purchased equipment.
Criteria or specific requirement: Per ?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 (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. Per the Organization's additions to Property and Equipment Policy, expenditures for tangible assets used actively in business operations with a cost exceeding $5,000 and with a useful life exceeding two years should be capitalized. Also per ?200.313, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Condition: We noted the Organization is not in compliance with requirements related to the Equipment/Real Property Management of grants. Questioned costs: None. Context: During our testing, we noted the following exceptions: ? 1 out of 2 equipment samples totaling $13,306 was not capitalized and therefore not included in the either the departments fixed asset software or year end Property and Equipment financial balance. This asset was originally purchased in fiscal year 2021. As such, the auditor could not trace the equipment to a listing and properly identify the equipment through physical inspection. ? The organization did not complete the required 2 year physical inventory of equipment for 1 out of 1 federally purchased equipment. The equipment was originally purchased in June 2020. ? The Organization was not aware of the Equipment/Real Property Management CFR Requirements and lacks a process to ensure the Organization is in compliance with Equipment/Real Property Management CFR requirements. Cause: Management oversight; lack of effective internal controls addressing the purchase of equipment with Federal Funds. Effect: The auditor noted instances of noncompliance. Noncompliance can result in delayed reimbursement of eligible Federal expenditures or potential loss of Federal funding. Repeat Finding: Yes ? 2021-001 Recommendation: We recommend that the Organization create effective internal controls and procedures over the purchase of Federally Funded Equipment and Real Property and a tracking methodology to properly identify equipment purchased with federal funds that allows for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants. Views of responsible officials: The Organization did have two purchases in FY21 that were expensed versus being capitalized. The Organization failed to follow the capital purchasing policy. The Organization has educated responsible parties of the capital purchasing policy to avoid future occurrences. The Organization has updated processes in fiscal year 2023 to ensure the purchasing policy is followed. The executive director of the program will conduct an annual physical inventory of federal purchased equipment.
2021-003 – ALLOWABLE COSTS/COST PRINCIPLES-PAYROLL DOCUMENTATION (Continued) Federal Program Information: Federal Agency Federal Program Name Assistance Listing Number Grant Award(s) Unique Identifier(s) Department of Defense Basic Scientific Research 12.431 W15QKN-14-1-0001 W15QKN-20-1-1000 (C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. (3) In accordance with Department of Labor regulations implementing the Fair Labor Standards Act (FLSA) (29 CFR part 516), charges for the salaries and wages of nonexempt employees, in addition to the supporting documentation described in this section, must also be supported by records indicating the total number of hours worked each day. 2 CFR 200.313 stipulates the identification with the Federal award rather than the nature of the goods and services involved is the determining factor in distinguishing direct from indirect (F&A) costs of Federal awards. Typical costs charged directly to a Federal award are the compensation of employees who work on that award, their related fringe benefit costs, the costs of materials and other items of expense incurred for the Federal award. If directly related to a specific award, certain costs that otherwise would be treated as indirect costs may also be considered direct costs. 2 CFR 200.414 stipulates that because of the diverse characteristics and accounting practices of nonprofit organizations, it is not possible to specify the types of cost which may be classified as indirect (F&A) cost in all situations. Identification with a Federal award rather than the nature of the goods and services involved is the determining factor in distinguishing direct from indirect (F&A) costs of Federal awards. However, typical examples of indirect (F&A) cost for many nonprofit organizations may include depreciation on buildings and equipment, the costs of operating and maintaining facilities, and general administration and general expenses, such as the salaries and expenses of executive officers, personnel administration, and accounting. SECTION III – FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (Continued) 2021-003 – ALLOWABLE COSTS/COST PRINCIPLES-PAYROLL DOCUMENTATION (Continued) Federal Program Information: Federal Agency Federal Program Name Assistance Listing Number Grant Award(s) Unique Identifier(s) Department of Defense Basic Scientific Research 12.431 W15QKN-14-1-0001 W15QKN-20-1-1000 Condition: All employees paid with federal funds are paid a fixed salary pursuant to an employment contract established prior to the calendar year. Estimates for salaries were made prior to the services being performed. However, there was a lack of documentation, which substantiates that the payroll charged was accurate, allowable and properly allocated. Furthermore, there was no documentation of days or hours worked per day in accordance with federal guidelines. Officials recorded all personnel costs as indirect (which is consistent with the treatment of these expenses in prior years) expenses. However, the budget award document indicates a large portion of personnel costs to be classified as direct charges. Questioned Costs: Unknown. Context: Salaries and related fringe benefits of $576,127 were expended under the federal award. Total federal expenditures listed on the Schedule of Federal Awards was $6,267,848. Cause: Internal controls and procedures related to the payroll documentation were not effectively designed or performed. Effect: National Center for the Advancement of STEM Education, Inc. is not in compliance with the documentation requirements related to salaries and wages. Recommendation: We recommend that management implement policies and procedures to ensure that documentation of salaries and wages are maintained in a manner consistent with federal requirements. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2021-003 – ALLOWABLE COSTS/COST PRINCIPLES-PAYROLL DOCUMENTATION (Continued) Federal Program Information: Federal Agency Federal Program Name Assistance Listing Number Grant Award(s) Unique Identifier(s) Department of Defense Basic Scientific Research 12.431 W15QKN-14-1-0001 W15QKN-20-1-1000 (C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. (3) In accordance with Department of Labor regulations implementing the Fair Labor Standards Act (FLSA) (29 CFR part 516), charges for the salaries and wages of nonexempt employees, in addition to the supporting documentation described in this section, must also be supported by records indicating the total number of hours worked each day. 2 CFR 200.313 stipulates the identification with the Federal award rather than the nature of the goods and services involved is the determining factor in distinguishing direct from indirect (F&A) costs of Federal awards. Typical costs charged directly to a Federal award are the compensation of employees who work on that award, their related fringe benefit costs, the costs of materials and other items of expense incurred for the Federal award. If directly related to a specific award, certain costs that otherwise would be treated as indirect costs may also be considered direct costs. 2 CFR 200.414 stipulates that because of the diverse characteristics and accounting practices of nonprofit organizations, it is not possible to specify the types of cost which may be classified as indirect (F&A) cost in all situations. Identification with a Federal award rather than the nature of the goods and services involved is the determining factor in distinguishing direct from indirect (F&A) costs of Federal awards. However, typical examples of indirect (F&A) cost for many nonprofit organizations may include depreciation on buildings and equipment, the costs of operating and maintaining facilities, and general administration and general expenses, such as the salaries and expenses of executive officers, personnel administration, and accounting. SECTION III – FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (Continued) 2021-003 – ALLOWABLE COSTS/COST PRINCIPLES-PAYROLL DOCUMENTATION (Continued) Federal Program Information: Federal Agency Federal Program Name Assistance Listing Number Grant Award(s) Unique Identifier(s) Department of Defense Basic Scientific Research 12.431 W15QKN-14-1-0001 W15QKN-20-1-1000 Condition: All employees paid with federal funds are paid a fixed salary pursuant to an employment contract established prior to the calendar year. Estimates for salaries were made prior to the services being performed. However, there was a lack of documentation, which substantiates that the payroll charged was accurate, allowable and properly allocated. Furthermore, there was no documentation of days or hours worked per day in accordance with federal guidelines. Officials recorded all personnel costs as indirect (which is consistent with the treatment of these expenses in prior years) expenses. However, the budget award document indicates a large portion of personnel costs to be classified as direct charges. Questioned Costs: Unknown. Context: Salaries and related fringe benefits of $576,127 were expended under the federal award. Total federal expenditures listed on the Schedule of Federal Awards was $6,267,848. Cause: Internal controls and procedures related to the payroll documentation were not effectively designed or performed. Effect: National Center for the Advancement of STEM Education, Inc. is not in compliance with the documentation requirements related to salaries and wages. Recommendation: We recommend that management implement policies and procedures to ensure that documentation of salaries and wages are maintained in a manner consistent with federal requirements. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2021-007 — Equipment and Real Property Management Federal/state program information: Funding agency: U.S. Department of Health and Human Services Title: Indian Self-Determination ALN: 93.441 Award period: 10/1/2020 – 9/30/2021 Criteria: 2 CFR section 200.313 requires that (1) equipment be used in the program or project for which it was acquired as long as needed, (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, and cost of the property, and (3) a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Additionally, CBNHC’s Financial Policies and Procedures require a physical inventory of property be taken annually and reconciled to the general ledger. Condition: CBNHC has not completed a physical inventory of property and equipment in the last two years. Context: N/A Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic. Additionally, CBNHC is not implementing their Financial Policies and Procedures to ensure that a physical inventory has been taken annually and reconciled to the general ledger. Effect: CBNHC is not in compliance with equipment and real property management requirements for the Indian Self-Determination program. Auditor’s Recommendations: CBNHC should implement its Financial Policies and Procedures and plan a physical inventory of its property as quickly as possible. The results of the physical inventory should be reconciled to the general ledger. Management’s Response: CBNHC did not have the adequate financial or administrative staff to perform a physical inventory and therefore has not been keeping with its Financial Policies and Procedures and performing an annual physical inventory.
Finding No. 2021-018 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.313(b)), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and procedures. The CNMI Property Management Policies and Procedures requires the Division of Procurement & Supply (PS) to conduct an annual inventory of property held by a designated official who has administrative control over the use of personal property within his area of jurisdiction. Also, PS shall perform random audits of property held by each accountable person to validate the integrity of the property control process. Further, 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 sale price of the property. Condition: 1. Tests of internal controls noted that a complete physical inventory of equipment and property was not performed by PS in FY 2021. 2. A property listing was provided by PS; however, information such as the federal award identification number, source of the property, who holds title, percentage of federal participation in the cost of the property, and use of the property, was not documented. 3. A variance of $415,046 was noted between the general ledger details of $665,165 of capital assets and $250,119 per the property listing provided by PS. Cause: The CNMI lacks the human resources and financial management system structure needed to effect compliance with applicable equipment and real property management requirements. Finding No. 2021-018, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Effect: The CNMI is in noncompliance with applicable equipment and real property management requirements. See below for the cumulative dollar amount of property and equipment acquired with program grant funds over the past five years. Identification as a Repeat Finding: Finding No. 2020-030 Recommendation: The CNMI should consider seeking technical and financial support from Federal agencies to develop human resources and a financial management system capable of effecting compliance with applicable property management policies and procedures. Views of responsible officials: Conditions 1 and 2 – The CNMI Corrective Action Plan states agreement. Condition 3 - The Division of Procurement Services disagrees with this finding. The Division of Procurement Services, Property Management wasn't informed of this audit parameter. For FY2021 number of Transactions/Units processed was 4970 units and the dollar value is $9,526,239. Auditor Response: Condition 3 - The request was for the inventory listing as of 09/30/21 fiscal year end. Further, the dollar amount of the equipment and property are all capital assets in excess of $5,000.
Finding No. 2021-018 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.313(b)), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and procedures. The CNMI Property Management Policies and Procedures requires the Division of Procurement & Supply (PS) to conduct an annual inventory of property held by a designated official who has administrative control over the use of personal property within his area of jurisdiction. Also, PS shall perform random audits of property held by each accountable person to validate the integrity of the property control process. Further, 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 sale price of the property. Condition: 1. Tests of internal controls noted that a complete physical inventory of equipment and property was not performed by PS in FY 2021. 2. A property listing was provided by PS; however, information such as the federal award identification number, source of the property, who holds title, percentage of federal participation in the cost of the property, and use of the property, was not documented. 3. A variance of $415,046 was noted between the general ledger details of $665,165 of capital assets and $250,119 per the property listing provided by PS. Cause: The CNMI lacks the human resources and financial management system structure needed to effect compliance with applicable equipment and real property management requirements. Finding No. 2021-018, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Effect: The CNMI is in noncompliance with applicable equipment and real property management requirements. See below for the cumulative dollar amount of property and equipment acquired with program grant funds over the past five years. Identification as a Repeat Finding: Finding No. 2020-030 Recommendation: The CNMI should consider seeking technical and financial support from Federal agencies to develop human resources and a financial management system capable of effecting compliance with applicable property management policies and procedures. Views of responsible officials: Conditions 1 and 2 – The CNMI Corrective Action Plan states agreement. Condition 3 - The Division of Procurement Services disagrees with this finding. The Division of Procurement Services, Property Management wasn't informed of this audit parameter. For FY2021 number of Transactions/Units processed was 4970 units and the dollar value is $9,526,239. Auditor Response: Condition 3 - The request was for the inventory listing as of 09/30/21 fiscal year end. Further, the dollar amount of the equipment and property are all capital assets in excess of $5,000.
Finding No. 2021-018 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.313(b)), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and procedures. The CNMI Property Management Policies and Procedures requires the Division of Procurement & Supply (PS) to conduct an annual inventory of property held by a designated official who has administrative control over the use of personal property within his area of jurisdiction. Also, PS shall perform random audits of property held by each accountable person to validate the integrity of the property control process. Further, 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 sale price of the property. Condition: 1. Tests of internal controls noted that a complete physical inventory of equipment and property was not performed by PS in FY 2021. 2. A property listing was provided by PS; however, information such as the federal award identification number, source of the property, who holds title, percentage of federal participation in the cost of the property, and use of the property, was not documented. 3. A variance of $415,046 was noted between the general ledger details of $665,165 of capital assets and $250,119 per the property listing provided by PS. Cause: The CNMI lacks the human resources and financial management system structure needed to effect compliance with applicable equipment and real property management requirements. Finding No. 2021-018, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Effect: The CNMI is in noncompliance with applicable equipment and real property management requirements. See below for the cumulative dollar amount of property and equipment acquired with program grant funds over the past five years. Identification as a Repeat Finding: Finding No. 2020-030 Recommendation: The CNMI should consider seeking technical and financial support from Federal agencies to develop human resources and a financial management system capable of effecting compliance with applicable property management policies and procedures. Views of responsible officials: Conditions 1 and 2 – The CNMI Corrective Action Plan states agreement. Condition 3 - The Division of Procurement Services disagrees with this finding. The Division of Procurement Services, Property Management wasn't informed of this audit parameter. For FY2021 number of Transactions/Units processed was 4970 units and the dollar value is $9,526,239. Auditor Response: Condition 3 - The request was for the inventory listing as of 09/30/21 fiscal year end. Further, the dollar amount of the equipment and property are all capital assets in excess of $5,000.
Finding No. 2021-018 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.313(b)), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and procedures. The CNMI Property Management Policies and Procedures requires the Division of Procurement & Supply (PS) to conduct an annual inventory of property held by a designated official who has administrative control over the use of personal property within his area of jurisdiction. Also, PS shall perform random audits of property held by each accountable person to validate the integrity of the property control process. Further, 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 sale price of the property. Condition: 1. Tests of internal controls noted that a complete physical inventory of equipment and property was not performed by PS in FY 2021. 2. A property listing was provided by PS; however, information such as the federal award identification number, source of the property, who holds title, percentage of federal participation in the cost of the property, and use of the property, was not documented. 3. A variance of $415,046 was noted between the general ledger details of $665,165 of capital assets and $250,119 per the property listing provided by PS. Cause: The CNMI lacks the human resources and financial management system structure needed to effect compliance with applicable equipment and real property management requirements. Finding No. 2021-018, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Effect: The CNMI is in noncompliance with applicable equipment and real property management requirements. See below for the cumulative dollar amount of property and equipment acquired with program grant funds over the past five years. Identification as a Repeat Finding: Finding No. 2020-030 Recommendation: The CNMI should consider seeking technical and financial support from Federal agencies to develop human resources and a financial management system capable of effecting compliance with applicable property management policies and procedures. Views of responsible officials: Conditions 1 and 2 – The CNMI Corrective Action Plan states agreement. Condition 3 - The Division of Procurement Services disagrees with this finding. The Division of Procurement Services, Property Management wasn't informed of this audit parameter. For FY2021 number of Transactions/Units processed was 4970 units and the dollar value is $9,526,239. Auditor Response: Condition 3 - The request was for the inventory listing as of 09/30/21 fiscal year end. Further, the dollar amount of the equipment and property are all capital assets in excess of $5,000.
Finding No. 2021-018 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.313(b)), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and procedures. The CNMI Property Management Policies and Procedures requires the Division of Procurement & Supply (PS) to conduct an annual inventory of property held by a designated official who has administrative control over the use of personal property within his area of jurisdiction. Also, PS shall perform random audits of property held by each accountable person to validate the integrity of the property control process. Further, 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 sale price of the property. Condition: 1. Tests of internal controls noted that a complete physical inventory of equipment and property was not performed by PS in FY 2021. 2. A property listing was provided by PS; however, information such as the federal award identification number, source of the property, who holds title, percentage of federal participation in the cost of the property, and use of the property, was not documented. 3. A variance of $415,046 was noted between the general ledger details of $665,165 of capital assets and $250,119 per the property listing provided by PS. Cause: The CNMI lacks the human resources and financial management system structure needed to effect compliance with applicable equipment and real property management requirements. Finding No. 2021-018, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Effect: The CNMI is in noncompliance with applicable equipment and real property management requirements. See below for the cumulative dollar amount of property and equipment acquired with program grant funds over the past five years. Identification as a Repeat Finding: Finding No. 2020-030 Recommendation: The CNMI should consider seeking technical and financial support from Federal agencies to develop human resources and a financial management system capable of effecting compliance with applicable property management policies and procedures. Views of responsible officials: Conditions 1 and 2 – The CNMI Corrective Action Plan states agreement. Condition 3 - The Division of Procurement Services disagrees with this finding. The Division of Procurement Services, Property Management wasn't informed of this audit parameter. For FY2021 number of Transactions/Units processed was 4970 units and the dollar value is $9,526,239. Auditor Response: Condition 3 - The request was for the inventory listing as of 09/30/21 fiscal year end. Further, the dollar amount of the equipment and property are all capital assets in excess of $5,000.
Finding Number: 2021-008 Prior Year Finding Number: 2020-008 Compliance Requirement: Equipment and Real Property Management Program: U.S. Department of Transportation Airport Improvement Program ALN: 20.106 Award #: Various Award Year: Various Criteria – Per 2 CFR section 200.313, Equipment, 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, 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 conditions of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Further, a physical inventory of equipment should be taken at least once every 2 years and reconciled to the equipment records along with the usage of an appropriate control system to safeguard and maintain equipment. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – We noted that the Authority maintains an equipment listing for fixed assets purchased with federal funding. However, the Authority was unable to provide complete property records which met the stated requirements. Additionally, the Authority did not conduct a physical inventory count of equipment in the last two years. The most recent physical inventory count was performed during fiscal year 2017. Further, it does not appear that internal controls over compliance are operating at a level of precision to ensure compliance with the equipment management compliance requirements. Cause – The internal controls established for the records maintenance and physical inventory count did not fully operate as designed causing the Authority to fall out of compliance with the required timing of such physical inventory count. Effect or Potential Effect – There is a risk that inadequate monitoring of equipment could lead to misappropriation of assets and noncompliance with Federal regulations resulting in a return of Federal awards received. Questioned Costs – None. Context – This is a condition identified per review of the Authority’s compliance with the specified requirements. Recommendation – We recommend that the Authority improve internal controls to ensure adherence to Federal regulations related to equipment record maintenance and physical inventory counts. There should be timely coordination and communication among all departments responsible for handling and managing such assets. Views of Responsible Officials - The Authority concurs with the auditor’s findings and recommendations. The Authority recognize the importance of maintaining accurate and complete property records for fixed assets purchased with federal funding. A complete fixed asset inventory was conducted in 2023 and is now performed annually. The planned corrective actions are presented in the Authority’s Corrective Action Plan, which is attached as Appendix B.
Finding Number: 2021-008 Prior Year Finding Number: 2020-008 Compliance Requirement: Equipment and Real Property Management Program: U.S. Department of Transportation Airport Improvement Program ALN: 20.106 Award #: Various Award Year: Various Criteria – Per 2 CFR section 200.313, Equipment, 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, 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 conditions of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Further, a physical inventory of equipment should be taken at least once every 2 years and reconciled to the equipment records along with the usage of an appropriate control system to safeguard and maintain equipment. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – We noted that the Authority maintains an equipment listing for fixed assets purchased with federal funding. However, the Authority was unable to provide complete property records which met the stated requirements. Additionally, the Authority did not conduct a physical inventory count of equipment in the last two years. The most recent physical inventory count was performed during fiscal year 2017. Further, it does not appear that internal controls over compliance are operating at a level of precision to ensure compliance with the equipment management compliance requirements. Cause – The internal controls established for the records maintenance and physical inventory count did not fully operate as designed causing the Authority to fall out of compliance with the required timing of such physical inventory count. Effect or Potential Effect – There is a risk that inadequate monitoring of equipment could lead to misappropriation of assets and noncompliance with Federal regulations resulting in a return of Federal awards received. Questioned Costs – None. Context – This is a condition identified per review of the Authority’s compliance with the specified requirements. Recommendation – We recommend that the Authority improve internal controls to ensure adherence to Federal regulations related to equipment record maintenance and physical inventory counts. There should be timely coordination and communication among all departments responsible for handling and managing such assets. Views of Responsible Officials - The Authority concurs with the auditor’s findings and recommendations. The Authority recognize the importance of maintaining accurate and complete property records for fixed assets purchased with federal funding. A complete fixed asset inventory was conducted in 2023 and is now performed annually. The planned corrective actions are presented in the Authority’s Corrective Action Plan, which is attached as Appendix B.
2021-007 — Equipment and Real Property Management Federal/state program information: Funding agency: U.S. Department of Health and Human Services Title: Indian Self-Determination ALN: 93.441 Award period: 10/1/2020 – 9/30/2021 Criteria: 2 CFR section 200.313 requires that (1) equipment be used in the program or project for which it was acquired as long as needed, (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, and cost of the property, and (3) a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Additionally, CBNHC’s Financial Policies and Procedures require a physical inventory of property be taken annually and reconciled to the general ledger. Condition: CBNHC has not completed a physical inventory of property and equipment in the last two years. Context: N/A Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic. Additionally, CBNHC is not implementing their Financial Policies and Procedures to ensure that a physical inventory has been taken annually and reconciled to the general ledger. Effect: CBNHC is not in compliance with equipment and real property management requirements for the Indian Self-Determination program. Auditor’s Recommendations: CBNHC should implement its Financial Policies and Procedures and plan a physical inventory of its property as quickly as possible. The results of the physical inventory should be reconciled to the general ledger. Management’s Response: CBNHC did not have the adequate financial or administrative staff to perform a physical inventory and therefore has not been keeping with its Financial Policies and Procedures and performing an annual physical inventory.
Finding No. 2021-018 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.313(b)), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and procedures. The CNMI Property Management Policies and Procedures requires the Division of Procurement & Supply (PS) to conduct an annual inventory of property held by a designated official who has administrative control over the use of personal property within his area of jurisdiction. Also, PS shall perform random audits of property held by each accountable person to validate the integrity of the property control process. Further, 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 sale price of the property. Condition: 1. Tests of internal controls noted that a complete physical inventory of equipment and property was not performed by PS in FY 2021. 2. A property listing was provided by PS; however, information such as the federal award identification number, source of the property, who holds title, percentage of federal participation in the cost of the property, and use of the property, was not documented. 3. A variance of $415,046 was noted between the general ledger details of $665,165 of capital assets and $250,119 per the property listing provided by PS. Cause: The CNMI lacks the human resources and financial management system structure needed to effect compliance with applicable equipment and real property management requirements. Finding No. 2021-018, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Effect: The CNMI is in noncompliance with applicable equipment and real property management requirements. See below for the cumulative dollar amount of property and equipment acquired with program grant funds over the past five years. Identification as a Repeat Finding: Finding No. 2020-030 Recommendation: The CNMI should consider seeking technical and financial support from Federal agencies to develop human resources and a financial management system capable of effecting compliance with applicable property management policies and procedures. Views of responsible officials: Conditions 1 and 2 – The CNMI Corrective Action Plan states agreement. Condition 3 - The Division of Procurement Services disagrees with this finding. The Division of Procurement Services, Property Management wasn't informed of this audit parameter. For FY2021 number of Transactions/Units processed was 4970 units and the dollar value is $9,526,239. Auditor Response: Condition 3 - The request was for the inventory listing as of 09/30/21 fiscal year end. Further, the dollar amount of the equipment and property are all capital assets in excess of $5,000.
Finding No. 2021-018 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.313(b)), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and procedures. The CNMI Property Management Policies and Procedures requires the Division of Procurement & Supply (PS) to conduct an annual inventory of property held by a designated official who has administrative control over the use of personal property within his area of jurisdiction. Also, PS shall perform random audits of property held by each accountable person to validate the integrity of the property control process. Further, 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 sale price of the property. Condition: 1. Tests of internal controls noted that a complete physical inventory of equipment and property was not performed by PS in FY 2021. 2. A property listing was provided by PS; however, information such as the federal award identification number, source of the property, who holds title, percentage of federal participation in the cost of the property, and use of the property, was not documented. 3. A variance of $415,046 was noted between the general ledger details of $665,165 of capital assets and $250,119 per the property listing provided by PS. Cause: The CNMI lacks the human resources and financial management system structure needed to effect compliance with applicable equipment and real property management requirements. Finding No. 2021-018, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Effect: The CNMI is in noncompliance with applicable equipment and real property management requirements. See below for the cumulative dollar amount of property and equipment acquired with program grant funds over the past five years. Identification as a Repeat Finding: Finding No. 2020-030 Recommendation: The CNMI should consider seeking technical and financial support from Federal agencies to develop human resources and a financial management system capable of effecting compliance with applicable property management policies and procedures. Views of responsible officials: Conditions 1 and 2 – The CNMI Corrective Action Plan states agreement. Condition 3 - The Division of Procurement Services disagrees with this finding. The Division of Procurement Services, Property Management wasn't informed of this audit parameter. For FY2021 number of Transactions/Units processed was 4970 units and the dollar value is $9,526,239. Auditor Response: Condition 3 - The request was for the inventory listing as of 09/30/21 fiscal year end. Further, the dollar amount of the equipment and property are all capital assets in excess of $5,000.
Finding No. 2021-018 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.313(b)), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and procedures. The CNMI Property Management Policies and Procedures requires the Division of Procurement & Supply (PS) to conduct an annual inventory of property held by a designated official who has administrative control over the use of personal property within his area of jurisdiction. Also, PS shall perform random audits of property held by each accountable person to validate the integrity of the property control process. Further, 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 sale price of the property. Condition: 1. Tests of internal controls noted that a complete physical inventory of equipment and property was not performed by PS in FY 2021. 2. A property listing was provided by PS; however, information such as the federal award identification number, source of the property, who holds title, percentage of federal participation in the cost of the property, and use of the property, was not documented. 3. A variance of $415,046 was noted between the general ledger details of $665,165 of capital assets and $250,119 per the property listing provided by PS. Cause: The CNMI lacks the human resources and financial management system structure needed to effect compliance with applicable equipment and real property management requirements. Finding No. 2021-018, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Effect: The CNMI is in noncompliance with applicable equipment and real property management requirements. See below for the cumulative dollar amount of property and equipment acquired with program grant funds over the past five years. Identification as a Repeat Finding: Finding No. 2020-030 Recommendation: The CNMI should consider seeking technical and financial support from Federal agencies to develop human resources and a financial management system capable of effecting compliance with applicable property management policies and procedures. Views of responsible officials: Conditions 1 and 2 – The CNMI Corrective Action Plan states agreement. Condition 3 - The Division of Procurement Services disagrees with this finding. The Division of Procurement Services, Property Management wasn't informed of this audit parameter. For FY2021 number of Transactions/Units processed was 4970 units and the dollar value is $9,526,239. Auditor Response: Condition 3 - The request was for the inventory listing as of 09/30/21 fiscal year end. Further, the dollar amount of the equipment and property are all capital assets in excess of $5,000.
Finding No. 2021-018 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.313(b)), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and procedures. The CNMI Property Management Policies and Procedures requires the Division of Procurement & Supply (PS) to conduct an annual inventory of property held by a designated official who has administrative control over the use of personal property within his area of jurisdiction. Also, PS shall perform random audits of property held by each accountable person to validate the integrity of the property control process. Further, 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 sale price of the property. Condition: 1. Tests of internal controls noted that a complete physical inventory of equipment and property was not performed by PS in FY 2021. 2. A property listing was provided by PS; however, information such as the federal award identification number, source of the property, who holds title, percentage of federal participation in the cost of the property, and use of the property, was not documented. 3. A variance of $415,046 was noted between the general ledger details of $665,165 of capital assets and $250,119 per the property listing provided by PS. Cause: The CNMI lacks the human resources and financial management system structure needed to effect compliance with applicable equipment and real property management requirements. Finding No. 2021-018, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Effect: The CNMI is in noncompliance with applicable equipment and real property management requirements. See below for the cumulative dollar amount of property and equipment acquired with program grant funds over the past five years. Identification as a Repeat Finding: Finding No. 2020-030 Recommendation: The CNMI should consider seeking technical and financial support from Federal agencies to develop human resources and a financial management system capable of effecting compliance with applicable property management policies and procedures. Views of responsible officials: Conditions 1 and 2 – The CNMI Corrective Action Plan states agreement. Condition 3 - The Division of Procurement Services disagrees with this finding. The Division of Procurement Services, Property Management wasn't informed of this audit parameter. For FY2021 number of Transactions/Units processed was 4970 units and the dollar value is $9,526,239. Auditor Response: Condition 3 - The request was for the inventory listing as of 09/30/21 fiscal year end. Further, the dollar amount of the equipment and property are all capital assets in excess of $5,000.
Finding No. 2021-018 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.313(b)), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and procedures. The CNMI Property Management Policies and Procedures requires the Division of Procurement & Supply (PS) to conduct an annual inventory of property held by a designated official who has administrative control over the use of personal property within his area of jurisdiction. Also, PS shall perform random audits of property held by each accountable person to validate the integrity of the property control process. Further, 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 sale price of the property. Condition: 1. Tests of internal controls noted that a complete physical inventory of equipment and property was not performed by PS in FY 2021. 2. A property listing was provided by PS; however, information such as the federal award identification number, source of the property, who holds title, percentage of federal participation in the cost of the property, and use of the property, was not documented. 3. A variance of $415,046 was noted between the general ledger details of $665,165 of capital assets and $250,119 per the property listing provided by PS. Cause: The CNMI lacks the human resources and financial management system structure needed to effect compliance with applicable equipment and real property management requirements. Finding No. 2021-018, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award Nos.: D14AP00037, D16AP00064 D16AP00065, D17AP00111, D18AP00031, D18AP00130, D18AP00146, D18AP00165, D20AP00099, D20AP00119, and D21AP10003 Area: Equipment and Real Property Management Questioned Costs: $-0- Effect: The CNMI is in noncompliance with applicable equipment and real property management requirements. See below for the cumulative dollar amount of property and equipment acquired with program grant funds over the past five years. Identification as a Repeat Finding: Finding No. 2020-030 Recommendation: The CNMI should consider seeking technical and financial support from Federal agencies to develop human resources and a financial management system capable of effecting compliance with applicable property management policies and procedures. Views of responsible officials: Conditions 1 and 2 – The CNMI Corrective Action Plan states agreement. Condition 3 - The Division of Procurement Services disagrees with this finding. The Division of Procurement Services, Property Management wasn't informed of this audit parameter. For FY2021 number of Transactions/Units processed was 4970 units and the dollar value is $9,526,239. Auditor Response: Condition 3 - The request was for the inventory listing as of 09/30/21 fiscal year end. Further, the dollar amount of the equipment and property are all capital assets in excess of $5,000.
Finding Number: 2021-008 Prior Year Finding Number: 2020-008 Compliance Requirement: Equipment and Real Property Management Program: U.S. Department of Transportation Airport Improvement Program ALN: 20.106 Award #: Various Award Year: Various Criteria – Per 2 CFR section 200.313, Equipment, 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, 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 conditions of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Further, a physical inventory of equipment should be taken at least once every 2 years and reconciled to the equipment records along with the usage of an appropriate control system to safeguard and maintain equipment. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – We noted that the Authority maintains an equipment listing for fixed assets purchased with federal funding. However, the Authority was unable to provide complete property records which met the stated requirements. Additionally, the Authority did not conduct a physical inventory count of equipment in the last two years. The most recent physical inventory count was performed during fiscal year 2017. Further, it does not appear that internal controls over compliance are operating at a level of precision to ensure compliance with the equipment management compliance requirements. Cause – The internal controls established for the records maintenance and physical inventory count did not fully operate as designed causing the Authority to fall out of compliance with the required timing of such physical inventory count. Effect or Potential Effect – There is a risk that inadequate monitoring of equipment could lead to misappropriation of assets and noncompliance with Federal regulations resulting in a return of Federal awards received. Questioned Costs – None. Context – This is a condition identified per review of the Authority’s compliance with the specified requirements. Recommendation – We recommend that the Authority improve internal controls to ensure adherence to Federal regulations related to equipment record maintenance and physical inventory counts. There should be timely coordination and communication among all departments responsible for handling and managing such assets. Views of Responsible Officials - The Authority concurs with the auditor’s findings and recommendations. The Authority recognize the importance of maintaining accurate and complete property records for fixed assets purchased with federal funding. A complete fixed asset inventory was conducted in 2023 and is now performed annually. The planned corrective actions are presented in the Authority’s Corrective Action Plan, which is attached as Appendix B.
Finding Number: 2021-008 Prior Year Finding Number: 2020-008 Compliance Requirement: Equipment and Real Property Management Program: U.S. Department of Transportation Airport Improvement Program ALN: 20.106 Award #: Various Award Year: Various Criteria – Per 2 CFR section 200.313, Equipment, 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, 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 conditions of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Further, a physical inventory of equipment should be taken at least once every 2 years and reconciled to the equipment records along with the usage of an appropriate control system to safeguard and maintain equipment. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – We noted that the Authority maintains an equipment listing for fixed assets purchased with federal funding. However, the Authority was unable to provide complete property records which met the stated requirements. Additionally, the Authority did not conduct a physical inventory count of equipment in the last two years. The most recent physical inventory count was performed during fiscal year 2017. Further, it does not appear that internal controls over compliance are operating at a level of precision to ensure compliance with the equipment management compliance requirements. Cause – The internal controls established for the records maintenance and physical inventory count did not fully operate as designed causing the Authority to fall out of compliance with the required timing of such physical inventory count. Effect or Potential Effect – There is a risk that inadequate monitoring of equipment could lead to misappropriation of assets and noncompliance with Federal regulations resulting in a return of Federal awards received. Questioned Costs – None. Context – This is a condition identified per review of the Authority’s compliance with the specified requirements. Recommendation – We recommend that the Authority improve internal controls to ensure adherence to Federal regulations related to equipment record maintenance and physical inventory counts. There should be timely coordination and communication among all departments responsible for handling and managing such assets. Views of Responsible Officials - The Authority concurs with the auditor’s findings and recommendations. The Authority recognize the importance of maintaining accurate and complete property records for fixed assets purchased with federal funding. A complete fixed asset inventory was conducted in 2023 and is now performed annually. The planned corrective actions are presented in the Authority’s Corrective Action Plan, which is attached as Appendix B.
Information on the federal program: Subject: Head Start Cluster – Equipment Federal Agency: Department of Health and Human Services Federal Program: Head Start Cluster Assistance Listing Number: 93.600 Compliance Requirement: Equipment Audit Finding: Material Weakness, Modified Opinion, Noncompliance Criteria: 45 CFR 75.308(c)(1) states in part: "For non-construction Federal awards, recipients must request prior approval from HHS awarding agencies for one or more of the following program or budget-related reasons: . . . (xi) The recipient wishes to dispose of, replace, or encumber title to real property, equipment, or intangible property that are acquired or improved with a Federal award. . . ." 45 CFR 75.323 states: "Real property, equipment, and intangible property, that are acquired or improved with a Federal award must be held in trust by the non-Federal entity as trustee for the beneficiaries of the project or program under which the property was acquired or improved. The HHS awarding agency may require the non-Federal entity to record liens or other appropriate notices of record to indicate that personal or real property has been acquired or improved with a Federal award and that use and disposition conditions apply to the property." 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 Unit to ensure compliance with requirements related to the grant agreement and the equipment compliance requirements. Cause: The Unit's management had not developed a system of internal controls to ensure compliance with the equipment requirements. Effect: The failure to establish an effective internal control system allowed noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: None. Context: During testing, we noted the Unit purchased eight buses in FY20 that each exceeded the $5,000 federal equipment threshold. However, the Unit did not perform any of the required federal compliance steps for equipment in FY21 (getting approval before making the purchase, adding the buses to the capital asset listing, and performing an inventory of the buses). The total cost of the buses, excluding interest costs on the loan, was approximately $649,000. The total annual payments, including interest from the loans, on the buses is approximately $177,000. The Unit initially believed the bus purchases were rental agreements which would not fall under federal compliance requirement. However, the purchases were loan agreements to purchases the buses. The Unit will own the buses after the final payment is made. Identification as a repeat finding, if applicable: This is a repeat finding from the immediately prior audit. The prior audit finding number was 2020-002. Recommendation: We recommend that the Unit perform the required steps to maintain compliance with the federal equipment compliance requirements. Section III – Federal Award Findings and Questioned Costs (Continued) Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Head Start Cluster – Equipment Federal Agency: Department of Health and Human Services Federal Program: Head Start Cluster Assistance Listing Number: 93.600 Compliance Requirement: Equipment Audit Finding: Material Weakness, Modified Opinion, Noncompliance Criteria: 45 CFR 75.308(c)(1) states in part: "For non-construction Federal awards, recipients must request prior approval from HHS awarding agencies for one or more of the following program or budget-related reasons: . . . (xi) The recipient wishes to dispose of, replace, or encumber title to real property, equipment, or intangible property that are acquired or improved with a Federal award. . . ." 45 CFR 75.323 states: "Real property, equipment, and intangible property, that are acquired or improved with a Federal award must be held in trust by the non-Federal entity as trustee for the beneficiaries of the project or program under which the property was acquired or improved. The HHS awarding agency may require the non-Federal entity to record liens or other appropriate notices of record to indicate that personal or real property has been acquired or improved with a Federal award and that use and disposition conditions apply to the property." 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 Unit to ensure compliance with requirements related to the grant agreement and the equipment compliance requirements. Cause: The Unit's management had not developed a system of internal controls to ensure compliance with the equipment requirements. Effect: The failure to establish an effective internal control system allowed noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: None. Context: During testing, we noted the Unit purchased eight buses in FY20 that each exceeded the $5,000 federal equipment threshold. However, the Unit did not perform any of the required federal compliance steps for equipment in FY21 (getting approval before making the purchase, adding the buses to the capital asset listing, and performing an inventory of the buses). The total cost of the buses, excluding interest costs on the loan, was approximately $649,000. The total annual payments, including interest from the loans, on the buses is approximately $177,000. The Unit initially believed the bus purchases were rental agreements which would not fall under federal compliance requirement. However, the purchases were loan agreements to purchases the buses. The Unit will own the buses after the final payment is made. Identification as a repeat finding, if applicable: This is a repeat finding from the immediately prior audit. The prior audit finding number was 2020-002. Recommendation: We recommend that the Unit perform the required steps to maintain compliance with the federal equipment compliance requirements. Section III – Federal Award Findings and Questioned Costs (Continued) Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Head Start Cluster – Equipment Federal Agency: Department of Health and Human Services Federal Program: Head Start Cluster Assistance Listing Number: 93.600 Compliance Requirement: Equipment Audit Finding: Material Weakness, Modified Opinion, Noncompliance Criteria: 45 CFR 75.308(c)(1) states in part: "For non-construction Federal awards, recipients must request prior approval from HHS awarding agencies for one or more of the following program or budget-related reasons: . . . (xi) The recipient wishes to dispose of, replace, or encumber title to real property, equipment, or intangible property that are acquired or improved with a Federal award. . . ." 45 CFR 75.323 states: "Real property, equipment, and intangible property, that are acquired or improved with a Federal award must be held in trust by the non-Federal entity as trustee for the beneficiaries of the project or program under which the property was acquired or improved. The HHS awarding agency may require the non-Federal entity to record liens or other appropriate notices of record to indicate that personal or real property has been acquired or improved with a Federal award and that use and disposition conditions apply to the property." 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 Unit to ensure compliance with requirements related to the grant agreement and the equipment compliance requirements. Cause: The Unit's management had not developed a system of internal controls to ensure compliance with the equipment requirements. Effect: The failure to establish an effective internal control system allowed noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: None. Context: During testing, we noted the Unit purchased eight buses in FY20 that each exceeded the $5,000 federal equipment threshold. However, the Unit did not perform any of the required federal compliance steps for equipment in FY21 (getting approval before making the purchase, adding the buses to the capital asset listing, and performing an inventory of the buses). The total cost of the buses, excluding interest costs on the loan, was approximately $649,000. The total annual payments, including interest from the loans, on the buses is approximately $177,000. The Unit initially believed the bus purchases were rental agreements which would not fall under federal compliance requirement. However, the purchases were loan agreements to purchases the buses. The Unit will own the buses after the final payment is made. Identification as a repeat finding, if applicable: This is a repeat finding from the immediately prior audit. The prior audit finding number was 2020-002. Recommendation: We recommend that the Unit perform the required steps to maintain compliance with the federal equipment compliance requirements. Section III – Federal Award Findings and Questioned Costs (Continued) Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Head Start Cluster – Equipment Federal Agency: Department of Health and Human Services Federal Program: Head Start Cluster Assistance Listing Number: 93.600 Compliance Requirement: Equipment Audit Finding: Material Weakness, Modified Opinion, Noncompliance Criteria: 45 CFR 75.308(c)(1) states in part: "For non-construction Federal awards, recipients must request prior approval from HHS awarding agencies for one or more of the following program or budget-related reasons: . . . (xi) The recipient wishes to dispose of, replace, or encumber title to real property, equipment, or intangible property that are acquired or improved with a Federal award. . . ." 45 CFR 75.323 states: "Real property, equipment, and intangible property, that are acquired or improved with a Federal award must be held in trust by the non-Federal entity as trustee for the beneficiaries of the project or program under which the property was acquired or improved. The HHS awarding agency may require the non-Federal entity to record liens or other appropriate notices of record to indicate that personal or real property has been acquired or improved with a Federal award and that use and disposition conditions apply to the property." 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 Unit to ensure compliance with requirements related to the grant agreement and the equipment compliance requirements. Cause: The Unit's management had not developed a system of internal controls to ensure compliance with the equipment requirements. Effect: The failure to establish an effective internal control system allowed noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: None. Context: During testing, we noted the Unit purchased eight buses in FY20 that each exceeded the $5,000 federal equipment threshold. However, the Unit did not perform any of the required federal compliance steps for equipment in FY21 (getting approval before making the purchase, adding the buses to the capital asset listing, and performing an inventory of the buses). The total cost of the buses, excluding interest costs on the loan, was approximately $649,000. The total annual payments, including interest from the loans, on the buses is approximately $177,000. The Unit initially believed the bus purchases were rental agreements which would not fall under federal compliance requirement. However, the purchases were loan agreements to purchases the buses. The Unit will own the buses after the final payment is made. Identification as a repeat finding, if applicable: This is a repeat finding from the immediately prior audit. The prior audit finding number was 2020-002. Recommendation: We recommend that the Unit perform the required steps to maintain compliance with the federal equipment compliance requirements. Section III – Federal Award Findings and Questioned Costs (Continued) Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Head Start Cluster – Equipment Federal Agency: Department of Health and Human Services Federal Program: Head Start Cluster Assistance Listing Number: 93.600 Compliance Requirement: Equipment Audit Finding: Material Weakness, Modified Opinion, Noncompliance Criteria: 45 CFR 75.308(c)(1) states in part: "For non-construction Federal awards, recipients must request prior approval from HHS awarding agencies for one or more of the following program or budget-related reasons: . . . (xi) The recipient wishes to dispose of, replace, or encumber title to real property, equipment, or intangible property that are acquired or improved with a Federal award. . . ." 45 CFR 75.323 states: "Real property, equipment, and intangible property, that are acquired or improved with a Federal award must be held in trust by the non-Federal entity as trustee for the beneficiaries of the project or program under which the property was acquired or improved. The HHS awarding agency may require the non-Federal entity to record liens or other appropriate notices of record to indicate that personal or real property has been acquired or improved with a Federal award and that use and disposition conditions apply to the property." 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 Unit to ensure compliance with requirements related to the grant agreement and the equipment compliance requirements. Cause: The Unit's management had not developed a system of internal controls to ensure compliance with the equipment requirements. Effect: The failure to establish an effective internal control system allowed noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: None. Context: During testing, we noted the Unit purchased eight buses in FY20 that each exceeded the $5,000 federal equipment threshold. However, the Unit did not perform any of the required federal compliance steps for equipment in FY21 (getting approval before making the purchase, adding the buses to the capital asset listing, and performing an inventory of the buses). The total cost of the buses, excluding interest costs on the loan, was approximately $649,000. The total annual payments, including interest from the loans, on the buses is approximately $177,000. The Unit initially believed the bus purchases were rental agreements which would not fall under federal compliance requirement. However, the purchases were loan agreements to purchases the buses. The Unit will own the buses after the final payment is made. Identification as a repeat finding, if applicable: This is a repeat finding from the immediately prior audit. The prior audit finding number was 2020-002. Recommendation: We recommend that the Unit perform the required steps to maintain compliance with the federal equipment compliance requirements. Section III – Federal Award Findings and Questioned Costs (Continued) Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Criteria: In accordance with 2 CFR 200.303, the College must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the College is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, 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 section 200.313(d)(1)). Condition: The College did not have the percentage of federal participation in the project costs for the federal award under which the property was acquired in the property records. Questioned Costs: None. Context: During our testing of property and equipment purchases, it was noted that the modular building purchased with federal funds did not have the percentage of federal participation included in the property records. For the year ended June 30, 2021, costs for the purchase of the modular building were $227,056, all of which were from federal funds. Additionally, the property had not been tagged as having been purchased with federal funds. Cause: The College did not have the percentage of federal participation as part of their property and equipment records. Effect: The College did not meet equipment property record requirements for equipment purchased with federal funds. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures to ensure all property and equipment purchased with federal funds includes such information in the property records to comply with the requirement. Views of responsible officials: Management agrees with the finding and has prepared a plan to correct the finding.
Criteria: In accordance with 2 CFR 200.303, the College must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the College is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, 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 section 200.313(d)(1)). Condition: The College did not have the percentage of federal participation in the project costs for the federal award under which the property was acquired in the property records. Questioned Costs: None. Context: During our testing of property and equipment purchases, it was noted that the modular building purchased with federal funds did not have the percentage of federal participation included in the property records. For the year ended June 30, 2021, costs for the purchase of the modular building were $227,056, all of which were from federal funds. Additionally, the property had not been tagged as having been purchased with federal funds. Cause: The College did not have the percentage of federal participation as part of their property and equipment records. Effect: The College did not meet equipment property record requirements for equipment purchased with federal funds. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures to ensure all property and equipment purchased with federal funds includes such information in the property records to comply with the requirement. Views of responsible officials: Management agrees with the finding and has prepared a plan to correct the finding.
Program Information: U.S. Department of the Interior AL # Award Number Award Period Program Name 15.042 A19AV00888 7/1/2020-6/30/2021 Indian School Equalization Program 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 Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)). 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 section 200.313(d)(2)). 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 section 200.313(d)(3)). 2 CFR § 200.303 - Internal controls states, the recipient and subrecipient must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: During the audit, we noted that a physical inventory of the School’s property had not been taken and reconciled with the property records within the last two years. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There was turnover in the School’s key accounting staff. Effect: Property records may not be accurate and proper custodianship of the property is compromised. Questioned Costs: N/A. Repeat Finding: Yes, 2020-001. Recommendation: We recommend that the School develop policies and procedures requiring a physical inventory of the School’s property at least once every two years, and reconcile the results of the inventory to the property records. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program: Charter School Programs Assistance Listing Number: 84.282 Federal Agency: U.S. Department of Education Pass-Through Grantor: New York State Education Department Award Identification: C403558 Criteria: Equipment and Real Property Management – The School must perform a physical inventory of federally funded property, and the results must be reconciled with property records at least once every two years. 2 CFR Section 200.313 Condition: During the course of our audit procedures performed on equipment and real property management, it was noted that management did not perform a physical inventory of federally funded property. Questioned costs: None Context: Management was unable to provide documentation to support that a physical inventory was performed. Effect: We were unable to verify compliance with equipment and real property management requirements. Cause: The School did not have adequate controls and procedures in place related to equipment and real property management. Repeat finding: This is not a repeat finding.
Information on the federal program: Subject: Head Start Cluster – Equipment Federal Agency: Department of Health and Human Services Federal Program: Head Start Cluster Assistance Listing Number: 93.600 Compliance Requirement: Equipment Audit Finding: Material Weakness, Modified Opinion, Noncompliance Criteria: 45 CFR 75.308(c)(1) states in part: "For non-construction Federal awards, recipients must request prior approval from HHS awarding agencies for one or more of the following program or budget-related reasons: . . . (xi) The recipient wishes to dispose of, replace, or encumber title to real property, equipment, or intangible property that are acquired or improved with a Federal award. . . ." 45 CFR 75.323 states: "Real property, equipment, and intangible property, that are acquired or improved with a Federal award must be held in trust by the non-Federal entity as trustee for the beneficiaries of the project or program under which the property was acquired or improved. The HHS awarding agency may require the non-Federal entity to record liens or other appropriate notices of record to indicate that personal or real property has been acquired or improved with a Federal award and that use and disposition conditions apply to the property." 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 Unit to ensure compliance with requirements related to the grant agreement and the equipment compliance requirements. Cause: The Unit's management had not developed a system of internal controls to ensure compliance with the equipment requirements. Effect: The failure to establish an effective internal control system allowed noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: None. Context: During testing, we noted the Unit purchased eight buses in FY20 that each exceeded the $5,000 federal equipment threshold. However, the Unit did not perform any of the required federal compliance steps for equipment in FY21 (getting approval before making the purchase, adding the buses to the capital asset listing, and performing an inventory of the buses). The total cost of the buses, excluding interest costs on the loan, was approximately $649,000. The total annual payments, including interest from the loans, on the buses is approximately $177,000. The Unit initially believed the bus purchases were rental agreements which would not fall under federal compliance requirement. However, the purchases were loan agreements to purchases the buses. The Unit will own the buses after the final payment is made. Identification as a repeat finding, if applicable: This is a repeat finding from the immediately prior audit. The prior audit finding number was 2020-002. Recommendation: We recommend that the Unit perform the required steps to maintain compliance with the federal equipment compliance requirements. Section III – Federal Award Findings and Questioned Costs (Continued) Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.