Finding Number: 2023-004 Federal Program: Airport Improvement Program Federal Award Identification Number and Year: All Airport Improvement Program awards, 2020, 2021, 2022, 2023 Assistance Listing Number (ALN): 20.106 Federal Awarding Agency: U.S. Department of Transportation Pass-through Entity: None Repeat Finding: No Material Weakness and Noncompliance – Reporting Criteria: Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMBapproved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances. (2 CFR 200.328). Until the grant is completed and closed, recipients are responsible for submitting formal reports as follows: A signed/dated SF-270 (non-construction projects) or SF-271 or equivalent (construction projects) and SF- 425 annually, due 90 days after the end of each federal fiscal year in which this grant is open (due December 31 of each year this grant is open). Condition: The Airport did not file the required reports within the timeframes above. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Standard Forms 425 and Standard Forms 271 for the reporting period ended September 30, 2023 were filed on January 19, 2024. Cause and Effect: The Airport did not prepare or submit the required forms by December 31, 2023. The SF-425 and SF-271 reports for the period ending September 30, 2023 were submitted 19 days after the due date. Recommendation: The Airport should implement controls and processes to ensure that the required reports are submitted timely. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2023-004 Federal Program: Airport Improvement Program Federal Award Identification Number and Year: All Airport Improvement Program awards, 2020, 2021, 2022, 2023 Assistance Listing Number (ALN): 20.106 Federal Awarding Agency: U.S. Department of Transportation Pass-through Entity: None Repeat Finding: No Material Weakness and Noncompliance – Reporting Criteria: Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMBapproved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances. (2 CFR 200.328). Until the grant is completed and closed, recipients are responsible for submitting formal reports as follows: A signed/dated SF-270 (non-construction projects) or SF-271 or equivalent (construction projects) and SF- 425 annually, due 90 days after the end of each federal fiscal year in which this grant is open (due December 31 of each year this grant is open). Condition: The Airport did not file the required reports within the timeframes above. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Standard Forms 425 and Standard Forms 271 for the reporting period ended September 30, 2023 were filed on January 19, 2024. Cause and Effect: The Airport did not prepare or submit the required forms by December 31, 2023. The SF-425 and SF-271 reports for the period ending September 30, 2023 were submitted 19 days after the due date. Recommendation: The Airport should implement controls and processes to ensure that the required reports are submitted timely. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2023-004 Federal Program: Airport Improvement Program Federal Award Identification Number and Year: All Airport Improvement Program awards, 2020, 2021, 2022, 2023 Assistance Listing Number (ALN): 20.106 Federal Awarding Agency: U.S. Department of Transportation Pass-through Entity: None Repeat Finding: No Material Weakness and Noncompliance – Reporting Criteria: Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMBapproved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances. (2 CFR 200.328). Until the grant is completed and closed, recipients are responsible for submitting formal reports as follows: A signed/dated SF-270 (non-construction projects) or SF-271 or equivalent (construction projects) and SF- 425 annually, due 90 days after the end of each federal fiscal year in which this grant is open (due December 31 of each year this grant is open). Condition: The Airport did not file the required reports within the timeframes above. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Standard Forms 425 and Standard Forms 271 for the reporting period ended September 30, 2023 were filed on January 19, 2024. Cause and Effect: The Airport did not prepare or submit the required forms by December 31, 2023. The SF-425 and SF-271 reports for the period ending September 30, 2023 were submitted 19 days after the due date. Recommendation: The Airport should implement controls and processes to ensure that the required reports are submitted timely. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2023-004 Federal Program: Airport Improvement Program Federal Award Identification Number and Year: All Airport Improvement Program awards, 2020, 2021, 2022, 2023 Assistance Listing Number (ALN): 20.106 Federal Awarding Agency: U.S. Department of Transportation Pass-through Entity: None Repeat Finding: No Material Weakness and Noncompliance – Reporting Criteria: Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMBapproved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances. (2 CFR 200.328). Until the grant is completed and closed, recipients are responsible for submitting formal reports as follows: A signed/dated SF-270 (non-construction projects) or SF-271 or equivalent (construction projects) and SF- 425 annually, due 90 days after the end of each federal fiscal year in which this grant is open (due December 31 of each year this grant is open). Condition: The Airport did not file the required reports within the timeframes above. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Standard Forms 425 and Standard Forms 271 for the reporting period ended September 30, 2023 were filed on January 19, 2024. Cause and Effect: The Airport did not prepare or submit the required forms by December 31, 2023. The SF-425 and SF-271 reports for the period ending September 30, 2023 were submitted 19 days after the due date. Recommendation: The Airport should implement controls and processes to ensure that the required reports are submitted timely. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2023-004 Federal Program: Airport Improvement Program Federal Award Identification Number and Year: All Airport Improvement Program awards, 2020, 2021, 2022, 2023 Assistance Listing Number (ALN): 20.106 Federal Awarding Agency: U.S. Department of Transportation Pass-through Entity: None Repeat Finding: No Material Weakness and Noncompliance – Reporting Criteria: Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMBapproved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances. (2 CFR 200.328). Until the grant is completed and closed, recipients are responsible for submitting formal reports as follows: A signed/dated SF-270 (non-construction projects) or SF-271 or equivalent (construction projects) and SF- 425 annually, due 90 days after the end of each federal fiscal year in which this grant is open (due December 31 of each year this grant is open). Condition: The Airport did not file the required reports within the timeframes above. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Standard Forms 425 and Standard Forms 271 for the reporting period ended September 30, 2023 were filed on January 19, 2024. Cause and Effect: The Airport did not prepare or submit the required forms by December 31, 2023. The SF-425 and SF-271 reports for the period ending September 30, 2023 were submitted 19 days after the due date. Recommendation: The Airport should implement controls and processes to ensure that the required reports are submitted timely. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2023-004 Federal Program: Airport Improvement Program Federal Award Identification Number and Year: All Airport Improvement Program awards, 2020, 2021, 2022, 2023 Assistance Listing Number (ALN): 20.106 Federal Awarding Agency: U.S. Department of Transportation Pass-through Entity: None Repeat Finding: No Material Weakness and Noncompliance – Reporting Criteria: Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMBapproved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances. (2 CFR 200.328). Until the grant is completed and closed, recipients are responsible for submitting formal reports as follows: A signed/dated SF-270 (non-construction projects) or SF-271 or equivalent (construction projects) and SF- 425 annually, due 90 days after the end of each federal fiscal year in which this grant is open (due December 31 of each year this grant is open). Condition: The Airport did not file the required reports within the timeframes above. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Standard Forms 425 and Standard Forms 271 for the reporting period ended September 30, 2023 were filed on January 19, 2024. Cause and Effect: The Airport did not prepare or submit the required forms by December 31, 2023. The SF-425 and SF-271 reports for the period ending September 30, 2023 were submitted 19 days after the due date. Recommendation: The Airport should implement controls and processes to ensure that the required reports are submitted timely. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Reporting Fiscal year ending :2023 Federal Program: Head Start 93.600 Questioned Costs: None Condition: During our audit, we noted that the Head Start program did not submit the required semi-annual form 425 and form 429 reports within the specified deadlines. The reports for the were submitted 10 and 15 days late, respectively. Criteria: According to 2 CFR Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), specifically 2 CFR § 200.328, recipients of federal awards must submit performance and financial reports to the federal awarding agency in a timely manner. The specific reporting deadlines are outlined in the award terms and conditions. Cause:The delay in submitting the reports was due to insufficient internal controls over the reporting process. Specifically, there was a lack of adequate staff training on the reporting requirements and no established procedures to ensure timely submission. Effect: Non-compliance with reporting requirements can result in delayed funding, reduced confidence from the federal awarding agency, and potential negative impacts on program operations. Continued noncompliance may also lead to more severe consequences such as the suspension of funding. Recommendation: We recommend that the Head Start program management take the requirements: Implement a formalized reporting schedule with clearly defined deadlines, establish a review process to verify the accuracy and timeliness of reports before submission and assign specific staff members to oversee compliance with reporting requirements. View of Responsible Officals: We will take the necessary steps to get clear deadlines from the awarding agency on the reporting dates for Head Start and update our formal reporting schedule with those dates. The Head Start Fund Accountant will work with the Administrative Assistant/Facilities Manager in gathering the necessary information earlier in the year for the yearly property reporting (SF-429). The Head Start Fund Accountant will email copies of these reports to the Director of Head Start to ensure compliance.
Reporting Fiscal year ending :2023 Federal Program: Head Start 93.600 Questioned Costs: None Condition: During our audit, we noted that the Head Start program did not submit the required semi-annual form 425 and form 429 reports within the specified deadlines. The reports for the were submitted 10 and 15 days late, respectively. Criteria: According to 2 CFR Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), specifically 2 CFR § 200.328, recipients of federal awards must submit performance and financial reports to the federal awarding agency in a timely manner. The specific reporting deadlines are outlined in the award terms and conditions. Cause:The delay in submitting the reports was due to insufficient internal controls over the reporting process. Specifically, there was a lack of adequate staff training on the reporting requirements and no established procedures to ensure timely submission. Effect: Non-compliance with reporting requirements can result in delayed funding, reduced confidence from the federal awarding agency, and potential negative impacts on program operations. Continued noncompliance may also lead to more severe consequences such as the suspension of funding. Recommendation: We recommend that the Head Start program management take the requirements: Implement a formalized reporting schedule with clearly defined deadlines, establish a review process to verify the accuracy and timeliness of reports before submission and assign specific staff members to oversee compliance with reporting requirements. View of Responsible Officals: We will take the necessary steps to get clear deadlines from the awarding agency on the reporting dates for Head Start and update our formal reporting schedule with those dates. The Head Start Fund Accountant will work with the Administrative Assistant/Facilities Manager in gathering the necessary information earlier in the year for the yearly property reporting (SF-429). The Head Start Fund Accountant will email copies of these reports to the Director of Head Start to ensure compliance.
Information on the Federal Program: Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds. Compliance Requirement: Reporting. Type of Finding: Significant deficiency in internal control over major federal programs. Criteria: The Uniform Guidance at 2 CFR 200.328 requires certain recipients of Coronavirus State and Local Fiscal Recovery Funds to submit quarterly and annual project and expenditure reports to the U.S. Department of the Treasury including, but not limited to, total obligations of funds, total expenditures of funds, and total number of projects. Condition: We noted that multiple quarterly reports did not accurately report total expenditures as of the date of the reporting period. Cause: Tracking spreadsheets were not appropriately updated to capture all expenditures of federal funds. Effect or Potential Effect: The County has a significant deficiency in internal control with respect to reporting of federal expenditures. Recommendation: Controls should require a secondary review and reconciliation of quarterly and annual reports to the County’s general ledger prior to submission by the grant director.
Section III – Federal Award Findings and Questioned Costs 2023-001: Compliance with Reporting Requirements (Repeat Finding) Federal Agency: Department of Health and Human Services (“HHS”), Health Resources and Services Administration (“HRSA”) Assistance Listing Program Title: Congressional Directives Federal Award Project Title: Community Project Funding/ Congressionally Directed Spending ‐ Construction Assistance Listing Number: 93.493 Federal Award Identification Number: CE146567 Criteria In accordance with 2 CFR 200.328 and the notice of award (“NoA”), there are financial and other reporting requirements that the entity must complete and submit to HHS. The NoA has the following financial and other reporting requirements that were subject to testing: 1. Within 90 days of project completion, a final report is required to be submitted. The project was completed on July 28, 2023 and the final report was required to be submitted by October 26, 2023; 2. A semi-annual progress report is required to be submitted every May and December until the project is completed. The first semi-annual progress report was due December 14, 2023 and; 3. The recipient must submit an annual Federal Financial Report (“FFR”), due October 30, 2023 for the annual period August 1, 2022 to July 31, 2023. Condition The conditions of the noncompliance identified are as follows: 4. The final report, due by October 26, 2023, was not submitted to HHS until August 13, 2024. 2. As the final report was not yet completed, the December semi-annual report was required to be submitted. The semi-annual report was submitted December 21, 2023, which was past the stated deadline of December 14, 2023. 3. The FFR submitted on October 24, 2023 for the period ended July 31, 2023 included $0 of federal expenditures when $749,892 of federal expenditures were incurred through the period ended July 31, 2023 based on our review of the underlying expenditure detail. Questioned Costs None Cause Management did not have an adequate understanding of the reporting requirements of the award and the control was not designed to ensure that reports were completed and submitted to the agency in a timely manner. Effect The late submission of the final report and the December 2023 semi-annual report and the submission of inaccurate financial data in the annual FFR causes Flushing to be out of compliance with specific grant reporting requirements. Recommendation We recommend Flushing enhance its control around the monitoring of grant reporting requirements, including evaluating report due dates, confirming reporting requirements with the granting agency as appropriate, and performing reviews prior to submission to ensure all reports are being completed accurately and submitted in a timely manner. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan is included at the end of this report.
Finding Number 2023-002 Assistance Listing #21.027 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Reporting Immaterial Noncompliance Criteria: In accordance with 2 CFR 200.328 and 31 CFR section 35.4(c) Reporting and requests for other information, grantees are required to file quarterly Project and Expenditure Reports listing significant projects, significant payments to subrecipients, subawards, and expenditure awards greater than $50,000. Condition: The Tribe incorrectly listed some project vendors as a subrecipients on the Project and Expenditure reports. Cause: Treasury guidance for reporting subrecipients versus contractors was in transition during the reporting periods for the year. Effect: The Tribe reported subrecipients on the Project and Expenditures Reports, but did not have any subrecipients of Coronavirus State and Local Fiscal Recovery Funds (SLFRF). Recommendation: Update reporting to ensure payments are reported as project vendors rather than subrecipients. Management's Response: Management recognizes that the error exists and has not been able to correct the report due to US Treasury’s portal not accepting prior period revisions. Treasury has changed its guidance on SLFRF multiple times over the past several years which has created an increased risk in filing errors for all reporting for these funds..
Finding Number: 2023-003 Federal Program: CDBG – Entitlement Grants Cluster Federal Award Identification Number and Year: B-22-MC-39-0001, 2022; B-20-MW-39-0001, 2020 Assistance Listing Number (ALN): 14.218 Federal Awarding Agency: Department of Housing and Urban Development Pass-through Entity: None Repeat Finding: No Material Weakness and Noncompliance – Reporting Criteria: Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances. (2 CFR 200.328). The Quarterly Cash on Hand report must be submitted to the respective field office within 30 days after the end of the reporting period. Condition: The City did not file the required reports within the timeframes above. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: The City submitted its Quarter 3 financial reports due July 30, 2023 on August 4, 2023. Cause and Effect: The City did not submit the required financial reports within the required timeframe. Recommendation: The City should implement controls and processes to ensure that the required reports are submitted timely. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2023-003 Federal Program: CDBG – Entitlement Grants Cluster Federal Award Identification Number and Year: B-22-MC-39-0001, 2022; B-20-MW-39-0001, 2020 Assistance Listing Number (ALN): 14.218 Federal Awarding Agency: Department of Housing and Urban Development Pass-through Entity: None Repeat Finding: No Material Weakness and Noncompliance – Reporting Criteria: Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances. (2 CFR 200.328). The Quarterly Cash on Hand report must be submitted to the respective field office within 30 days after the end of the reporting period. Condition: The City did not file the required reports within the timeframes above. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: The City submitted its Quarter 3 financial reports due July 30, 2023 on August 4, 2023. Cause and Effect: The City did not submit the required financial reports within the required timeframe. Recommendation: The City should implement controls and processes to ensure that the required reports are submitted timely. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2023-002 Federal Program: Staffing for Adequate Fire and Emergency Response 2020 Federal Award Identification Number and Year: EMW-2020-FF-00837, 2021 Assistance Listing Number (ALN): 97.083 Federal Awarding Agency: Federal Emergency Management Agency Pass-through Entity: None Repeat Finding: No Material Weakness and Noncompliance – Reporting Criteria: Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances. (2 CFR 200.328). Programmatic reports must be submitted through the Federal Emergency Management Agency’s (FEMA) GO portal no later than January 30 (for the period of July 1 – December 31) and no later than July 30 (for the period of January 1 – June 30). (FEMA Grant Programs Directorate Information Bulletin Number 468, dated April 4, 2022). Condition: The City did not file the required reports within the timeframes above. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: The City submitted its programmatic report due July 30, 2023 on December 1, 2023. The City submitted its programmatic report due January 30, 2024 on March 30, 2024. Cause and Effect: The City did not submit the required programmatic reports within the required timeframes. Recommendation: The City should implement controls and processes to ensure that the required reports are submitted timely. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
2 CFR § 200.328 provides the Federal awarding agency may solicit only the standard, OMB-approved governmentwide data elements for collection of financial information. This information must be collected with the frequency required by the terms and conditions of the Federal award.The American Rescue Plan Act Statewide Planning Award states that Grantee shall submit to Grantor Project Progress Reports. Grantee agrees to provide Grantor with project progress reports, communicating the important activities and accomplishments of the project, on a semi-annual basis for the period ending March 31 and September 30, or any portion thereof, for the entire project period. Reports are due no later than two weeks following the end of the semi-annual period. Reports shall be in clear format, not exceeding six pages, and shall: i. Document accomplishments, benefits, and impacts of the project. The Grantee should identify activities that have led to specific outcomes, such as job creation/retention, private investment, increased regional collaboration, engagement with historically excluded groups or regions, enhanced regional capacity, or other positive economic development benefits; ii. Identify any upcoming or potential press events or opportunities for collaborative press engagement to highlight the benefits of the award investment; iii. Compare progress on the project with the targeted schedule, explaining nay departures, identifying how those departures will be remedied, and projecting the course of work for the next semi-annual reporting period; iv. Outline challenges impending or that my impede progress on the project over the next semi-annual reporting period and identify ways to address those challenges; v. Outline any areas in which assistance is needed to support the project; and vi. Provide any other information that would be helpful for Grantor to know.The Project Progress Report for the semi-annual basis for the period ending March 31 contained the required information; however, due to insufficient controls over ensuring reports are submitted by the required due date, it was not submitted timely within the two weeks following the end of the semi-annual period and was submitted on October 16, 2023, six months late by the Commission.Failure to submit reports on a timely basis could result in delays in federal funding or other penalties and sanctions.The Commission should ensure that all federal reports are submitted timely.
2 CFR § 200.328 provides the Federal awarding agency may solicit only the standard, OMB-approved governmentwide data elements for collection of financial information. This information must be collected with the frequency required by the terms and conditions of the Federal award.The American Rescue Plan Act Statewide Planning Award states that Grantee shall submit to Grantor Project Progress Reports. Grantee agrees to provide Grantor with project progress reports, communicating the important activities and accomplishments of the project, on a semi-annual basis for the period ending March 31 and September 30, or any portion thereof, for the entire project period. Reports are due no later than two weeks following the end of the semi-annual period. Reports shall be in clear format, not exceeding six pages, and shall: i. Document accomplishments, benefits, and impacts of the project. The Grantee should identify activities that have led to specific outcomes, such as job creation/retention, private investment, increased regional collaboration, engagement with historically excluded groups or regions, enhanced regional capacity, or other positive economic development benefits; ii. Identify any upcoming or potential press events or opportunities for collaborative press engagement to highlight the benefits of the award investment; iii. Compare progress on the project with the targeted schedule, explaining nay departures, identifying how those departures will be remedied, and projecting the course of work for the next semi-annual reporting period; iv. Outline challenges impending or that my impede progress on the project over the next semi-annual reporting period and identify ways to address those challenges; v. Outline any areas in which assistance is needed to support the project; and vi. Provide any other information that would be helpful for Grantor to know.The Project Progress Report for the semi-annual basis for the period ending March 31 contained the required information; however, due to insufficient controls over ensuring reports are submitted by the required due date, it was not submitted timely within the two weeks following the end of the semi-annual period and was submitted on October 16, 2023, six months late by the Commission.Failure to submit reports on a timely basis could result in delays in federal funding or other penalties and sanctions.The Commission should ensure that all federal reports are submitted timely.
FINDING 2023-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): ILBC-2023-Body Camera-00052 Pass-Through Entity: Indiana Department of Homeland Security Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 13 KOSCIUSKO COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The County Sheriff applied for the Indiana Local Body Camera Grant (ILBC). The grant is a reimbursable grant through the Indiana Department of Homeland Security. The County Sheriff was awarded this grant on January 1, 2023, with a grant cost amount of up to $31,920 to be spent from January 1, 2023 to December 31, 2023. The County Sheriff ordered body-worn cameras and other equipment on April 26, 2023. A Reimbursement Claim Form (Form) was submitted for the cameras and other equipment on September 11, 2023. The Form shows the County Sheriff requested the full $31,920; however, the County had only spent $9,581 from the grant fund towards the purchase. The reimbursement of $31,920 from the Indiana Department of Homeland Security was received on September 27, 2023. The fund had a balance of $22,339 as of December 31, 2023. As there are no grant expenditures for the remaining reimbursements received and the period of performance had ended, the County should have reimbursed the Indiana Department of Homeland Security $22,339. On May 9, 2023, the County Sheriff's grant administrator submitted a Program Report for the ILBC grant. The report was completed and submitted by the County Sheriff's grant administrator without a documented oversight or review process to ensure the completeness and accuracy of the report. The report incorrectly indicated that all expenditures had been completed. However, as of the date of the submission, the County had not purchased the body-worn cameras, and all federal funds had not been expended. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." INDIANA STATE BOARD OF ACCOUNTS 14 KOSCIUSKO COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.344(d) states in part: "The non-Federal entity must promptly refund any balances of unobligated cash that the Federal awarding agency or pass-through entity paid in advance or paid and that are not authorized to be retained by the non-Federal entity for use in other projects. . . ." Cause A proper system of internal controls, which would include segregation of key functions, was not designed by management of the County to ensure the accuracy of the reimbursement invoice and the Program Report. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the County's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As such, federal reimbursement was requested in excess of the amount spent. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County establish a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place to ensure reimbursement invoices are complete and accurate prior to submission. Furthermore, we recommended the County contact the awarding agency to discuss the funds remaining. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Item 2023-001 – Financial Reporting: Federal Financial Report (SF425) Awarding Agency: U.S. Department of Defense Federal Program: 12.431 – U.S. Army Research Laboratory - Basic Scientific Research; 12.800 - U.S. Air Force Research Laboratory - Air Force Defense - Research Sciences Program Federal Award Identification Number: W911NF-22-2-0050, FA8650-13-2-5402 Grant Period: July 2022 to June 2025; September 2018 to December 2025 Criteria: During the course of the 2023 audit, it was noted during a discussion with management that the financial reports for the above-mentioned awards were not submitted timely. 2 CFR 200.328 requires the reporting of financial information by the auditee according to the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award. The Cooperative Agreements note that reporting period end dates fall on the end of the calendar year for annual reports (12/31) and the end date of the award for the final report. Annual reports are due 30 days after the reporting end date, and the final report is due 90 days after the end date. Condition: We determined that the required annual SF425 for federal award W911NF-22-2-0050 was due by January 31, 2024, and was not submitted as of June 2024. In addition, we determined that the annual SF425 for federal award FA8650-13-2-5402 was due on January 31, 2024, and was submitted on March 25, 2024. Cause: SEMI details the occurrence was due to an administrative oversight. Effect: The SF425 for federal awards W911NF-22-2-0050 and FA8650-13-2-5402 were not submitted timely. Questioned Cost: None Context: This is the first time that it was determined that a financial reporting form for one of their five awards was not submitted according to the required due date. Repeat Finding: No Recommendation: We recommend for management to implement process improvements to ensure financial reports are submitted by their required due dates. Views of Responsible Official: SEMI concurs with the finding and will evaluate process improvements to ensure financial reports are submitted by their required due dates or filing extensions are received in writing on a go-forward basis.
Item 2023-001 – Financial Reporting: Federal Financial Report (SF425) Awarding Agency: U.S. Department of Defense Federal Program: 12.431 – U.S. Army Research Laboratory - Basic Scientific Research; 12.800 - U.S. Air Force Research Laboratory - Air Force Defense - Research Sciences Program Federal Award Identification Number: W911NF-22-2-0050, FA8650-13-2-5402 Grant Period: July 2022 to June 2025; September 2018 to December 2025 Criteria: During the course of the 2023 audit, it was noted during a discussion with management that the financial reports for the above-mentioned awards were not submitted timely. 2 CFR 200.328 requires the reporting of financial information by the auditee according to the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award. The Cooperative Agreements note that reporting period end dates fall on the end of the calendar year for annual reports (12/31) and the end date of the award for the final report. Annual reports are due 30 days after the reporting end date, and the final report is due 90 days after the end date. Condition: We determined that the required annual SF425 for federal award W911NF-22-2-0050 was due by January 31, 2024, and was not submitted as of June 2024. In addition, we determined that the annual SF425 for federal award FA8650-13-2-5402 was due on January 31, 2024, and was submitted on March 25, 2024. Cause: SEMI details the occurrence was due to an administrative oversight. Effect: The SF425 for federal awards W911NF-22-2-0050 and FA8650-13-2-5402 were not submitted timely. Questioned Cost: None Context: This is the first time that it was determined that a financial reporting form for one of their five awards was not submitted according to the required due date. Repeat Finding: No Recommendation: We recommend for management to implement process improvements to ensure financial reports are submitted by their required due dates. Views of Responsible Official: SEMI concurs with the finding and will evaluate process improvements to ensure financial reports are submitted by their required due dates or filing extensions are received in writing on a go-forward basis.
2 CFR 1000.10 gives regulatory effect to the Department of Treasury for 2 CFR 200.328 which states: Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. The following have been determined to be Key Line Items for the State and Local Fiscal Recovery Fund Program (SLFRF) 1. Obligations and Expenditures - Quantificable Objective Criteria: Reported obligations and expenditures. a. Current period obligation b. Cumulative obligation c. Current period expenditure d. Cumulative expenditure. The County submitted the annual SLFRF Compliance Report for March 2023, however cumulative obligations, cumulative expenditures, current period obligations and current period expenditures, eaching totaling $5,227,729 were not reported. By not reporting obligation and expenditures, the County is underreporting its obligations and expenditures for the program and the report is not an accurate reflection of the County's SLFRF activity.
#2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Material Weakness in Internal Controls Over Compliance This is a partial repeat of prior year finding #2022-009. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing that no review procedures are in place surrounding these reports. Cause/Context: Controls were not in place to ensure accurate reporting. Only one individual was involved in the reporting process. Effect: Controls in place do not sufficiently ensure complete, accurate, and timely reporting compliance. Recommendation: We recommend that a full-range of controls related to reporting, including federal program reporting be implemented. The Organization should devote the resources necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval should be documented and that documentation be maintained. Views of Responsible Officials and Planned Corrective Actions: MARR will retain a CPA consultant to implement a full – range of controls relating to reporting, including federal program reporting. MARR will take such steps as necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval will be documented in such documentation to be maintained.
#2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Material Weakness in Internal Controls Over Compliance This is a partial repeat of prior year finding #2022-009. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing that no review procedures are in place surrounding these reports. Cause/Context: Controls were not in place to ensure accurate reporting. Only one individual was involved in the reporting process. Effect: Controls in place do not sufficiently ensure complete, accurate, and timely reporting compliance. Recommendation: We recommend that a full-range of controls related to reporting, including federal program reporting be implemented. The Organization should devote the resources necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval should be documented and that documentation be maintained. Views of Responsible Officials and Planned Corrective Actions: MARR will retain a CPA consultant to implement a full – range of controls relating to reporting, including federal program reporting. MARR will take such steps as necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval will be documented in such documentation to be maintained.
Cluster: Not applicable Federal Granting Agency: Department of Health and Human Services (“HHS”), Substance Abuse and Mental Health Services Administration (“SAMHSA”) Award Name: Congressional Directives Award Year: 2023 Assistance Listing #: 93.493 Federal Award Identification Number: 1H79FG000903-01 Criteria In accordance with 2 CFR 200.328 and the notice of award, there are other reporting requirements that the entity must complete and submit to HHS. Specifically, the Programmatic Report, as defined in the notice of award, is required on an annual basis and must be submitted as a .pdf to the View Terms Tracking Details page in the eRA Commons System no later than 90 days after the end of each 12-month budget period. Condition The Programmatic Report, which was due by December 28, 2023, was not submitted to the eRA Commons System until July 25, 2024. Cause Management initially did not have the accurate access to submit the report in the eRA Commons System. Once the access was resolved, management did not have an adequate understanding of the reporting requirements of the award and the control was not designed to ensure that the reports were completed and submitted to the agency in a timely manner. Effect The late submission of the Programmatic Report causes Franciscan to be out of compliance with specific grant reporting requirements. Questioned Costs None noted. Recommendation We recommend that Franciscan enhance its internal control around the monitoring of grant reporting requirements, including evaluating report due dates, confirming reporting requirements with the granting agency as appropriate, ensuring appropriate access to systems is maintained, and performing reviews prior to submission to ensure all reports are being completed accurately and submitted in a timely manner. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY 2023 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit Findings: Material Weakness, Modified Opinion Condition and Context Recipients may use COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) funds for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 and amended by the Consolidated Appropriations Act of 2023. The SLFRF program provides substantial flexibility for each recipient to meet local needs within seven separate eligible use categories. Recipients may use SLFRF funds to: Respond to the COVID-19 public health emergency and its negative economic impacts; Respond to workers performing essential work during the COVID-19 public health emergency by providing premium pay to eligible workers of eligible employers that have eligible workers who are performing essential work; Provide government services, to the extent COVID-19 caused a reduction in revenues collected in the most recent full fiscal year of the recipient; Make necessary investments in water, sewer, or broadband infrastructure; Provide emergency relief from natural disasters or their negative economic impacts; Fund eligible Surface Transportation projects; and Fund Title I projects that are eligible activities under the Community Development Block Grant and Indiana Community Development Block Grant programs. As part of sound management of the federal award, the City was responsible for implementing a system of internal controls that would ensure compliance with the applicable requirements. The City did not properly design or implement such a system. The City elected to receive the standard revenue loss allowance, allowing it to claim its total SLFRF allocation of $2,290,914 as revenue loss to use for government services. The allocated funds may only be used to cover costs incurred from the period beginning on March 3, 2021, and ending on December 31, 2024. Obligations for costs incurred are required to be liquidated no later than December 31, 2026 (the end of the period of performance). During the audit period, the City completed three separate transfers of SLFRF funds from the ARPA Coronavirus Local Fiscal fund to the Comm Crossing Grant Fund and Water Utility-Operating funds, totaling $976,431 and $494,159, respectively. The transfers allowed for federal grant funds to be commingled with other grant and operating funds. Subsequently, expenditures were disbursed from the Comm Crossing Grant Fund and Water Utility-Operating funds. However, since the transfer of SLFRF funds into the Comm Crossing Grant Fund and Water Utility-Operating funds commingled receipts, and the City did not ensure there was an appropriate system of internal controls in place to account for the federal expenditures separately from other grant and operating expenditures, we were unable to determine a complete population of federal expenditures. Without a complete population of expenditures, we were unable to determine the City's compliance with the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. As such, the $976,431 and $494,159 transferred from the ARPA Coronavirus Local Fiscal fund are considered questioned costs. The lack of internal controls and appropriate documentation to test the compliance requirements was isolated to the situation described above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.300(b) states in part: "The non-Federal entity is responsible for complying with all requirements of the Federal award. . . ." 2 CFR 200.302 states in part: "(a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. . . . (b) The financial management system of each non-Federal entity must provide for the following . . . (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number and year, name of the Federal agency, and name of the pass-through entity, if any. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. . . ." Cause Due to the lack of internal controls, the City was unable to differentiate expenditures made from federal and nonfederal funds once it commingled other grant, operating, and federal grant awards into a single fund within its ledger without consideration of the need to separately identify and account for federal expenditures. Effect Without the proper implementation of an effectively designed system of internal controls, the Town cannot identify the expenditures paid with federal grant funds. As such the Town cannot ensure nor can we determine that expenditures of the grant were not unallowable and fell within the period of performance. Questioned Costs We identified $1,470,590 in known questioned costs as noted above in the Condition and Context. Recommendation We recommended that management of the City establish a system of internal controls to ensure that grant award funds are accounted for and tracked in a designated grant fund. All activity of the grant should be in this fund with supporting documentation for each transaction. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Federal Agency: U.S. Department of Health and Human Services Assistance Listing Numbers: 93.550 & 93.623 Federal Program Titles: Transitional Living for Homeless Youth; Basic Center Grant Award Period: October 1, 2022 through September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations 2 CFR 200.328, Financial Reporting, requires that non-Federal entities must submit quarterly Federal Financial Reports within the timeframe prescribed by the terms and conditions of the Federal award. Condition: During our testing, we noted that the Organization did not submit the annual Federal Financial Report within the timeframe outlined in the grant agreement. Questioned Costs: None. Context: During our testing of performance and financial reports, The Adams Group, LLC noted the annual Federal Financial Reports for both ALNs 93.623 and 93.550 were submitted on January 26, 2024, which was four weeks past the deadline of December 30, 2023. Effect: The organization is not compliant with the reporting requirements of the cognizant oversight agency. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization implement a process to review the reporting requirements for all federal awards to ensure timely submission of reports. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Health and Human Services Assistance Listing Numbers: 93.550 & 93.623 Federal Program Titles: Transitional Living for Homeless Youth; Basic Center Grant Award Period: October 1, 2022 through September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations 2 CFR 200.328, Financial Reporting, requires that non-Federal entities must submit quarterly Federal Financial Reports within the timeframe prescribed by the terms and conditions of the Federal award. Condition: During our testing, we noted that the Organization did not submit the annual Federal Financial Report within the timeframe outlined in the grant agreement. Questioned Costs: None. Context: During our testing of performance and financial reports, The Adams Group, LLC noted the annual Federal Financial Reports for both ALNs 93.623 and 93.550 were submitted on January 26, 2024, which was four weeks past the deadline of December 30, 2023. Effect: The organization is not compliant with the reporting requirements of the cognizant oversight agency. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization implement a process to review the reporting requirements for all federal awards to ensure timely submission of reports. Views of Responsible Officials: Management agrees with the finding.
FINDING 2023-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, and Procurement and Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): PO 20011717 Pass-Through Entity: Indiana State Department of Health Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context The County Department of Health, a department within the County, was awarded the Health Issues and Challenges grant through the Indiana State Department of Health financed through the American Rescue Plan Act for the purpose of funding programs that focus on the improvement of chronic disease, specifically, elevated blood lead level reduction. The Health Issues and Challenges grant is a reimbursable grant, whereby the County received reimbursement on a per-case basis at a stated rate for Case Management and Environmental Investigation activities performed. The County Department of Health received federal receipts related to the grant in the amount of $130,479 during 2023. As part of sound management of the federal award, the County Department of Health was responsible for implementing a system of internal controls that would ensure compliance with the applicable requirements. The County Department of Health did not properly design or implement such a system. Receipts of the program were adequately identified through the use of an account number within the County Health Fund (285) in the County's ledger (ledger) which was unique to the Health Issues and Challenges grant receipts. However, the ledger did not adequately identify the expenditures of the grant program within the County Health Fund. Through inquiry with the County Department of Health employees and review of unit-prepared support of grant expenditures, we determined expenditures were made with grant funds during the audit period; however, we were unable to distinguish between the expenditures of the Health Issues and Challenges grant and all other activities of the County Department of Health in the County Health fund. Due to the lack of separate identification of expenditures in the financial records, we were not able to establish a population from which to audit the Health Issues and Challenges grant for compliance with the following compliance requirements of the program: Activities Allowed or Unallowed Allowable Costs/Cost Principles Period of Performance Procurement and Suspension and Debarment As such, the full award amount of $130,479, as reported on the Schedule of Expenditures of Federal Awards, was determined to be questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.300(b) states in part: "The non-Federal entity is responsible for complying with all requirements of the Federal award. . . ." 2 CFR 200.302 states in part: "(a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. . . . (b) The financial management system of each non-Federal entity must provide for the following . . . (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number and year, name of the Federal agency, and name of the pass-through entity, if any. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. . . ." Cause The County Department of Health was unable to differentiate expenditures made from federal and non-federal funds within its ledger for the Heath Issues and Challenges grant. Effect Without the proper implementation of an effectively designed system of internal controls, a population of expenditures associated with the Health Issues and Challenges grant could not be determined. As such, the County Department of Health cannot ensure nor can we determine that expenditures of the grant were not unallowable, within the proper period, and adhered to established practices and policies. Questioned Costs We identified $130,479 in known questioned costs as noted in the Condition and Context. Recommendation We recommended that management of the County Department of Health establish a system of internal controls to ensure that grant award funds are adequately accounted for and tracked in such a manner as to determine the activity, receipts, and disbursements associated with the grant. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-006 Subject: Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: U.S. Department of Treasury Assistance Listing Number: 21.027 Federal Award Number: FY 2021 Pass-Through Entity: N/A Compliance Requirements: Reporting Audit Findings: Significant Deficiency, Internal Controls Criteria: 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: The Town did not have a documented review control in place to ensure the annual report was reviewed by someone other than the preparer. Cause: There were not sufficient internal controls in place to ensure the accuracy of the annual report. Context: There was no documented review by someone other than the preparer of the annual report to ensure the information submitted was complete and accurate. Per discussion with management, verbal review occurred but there is no documentation to support that review occurred. Effect: The failure to establish an effective internal control system placed the Town at risk of noncompliance with the grant agreement and the Reporting compliance requirements. Identification as a repeat finding, if applicable: No Recommendation: We recommend someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY 2023 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to receipt of direct COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) award funds, all eligible entities were required to execute a Financial Assistance Agreement (Agreement) which included the Award Terms and Conditions that recipients must comply with in carrying out the objectives of their award. Per the Agreement, the Town was responsible for the effective administration of the federal award as well as the application of sound management practices and administration of federal funds in a manner consistent with program objectives and terms and conditions of the award. Recipients may use SLFRF funds for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 and amended by the Consolidated Appropriations Act of 2023. The SLFRF program provides substantial flexibility for each recipient to meet local needs within seven separate eligible use categories. Recipients may use SLFRF funds to: Respond to the COVID-19 public health emergency and its negative economic impacts; Respond to workers performing essential work during the COVID-19 public health emergency by providing premium pay to eligible workers of eligible employers that have eligible workers who are performing essential work; INDIANA STATE BOARD OF ACCOUNTS 17 TOWN OF UPLAND SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Provide government services, to the extent COVID-19 caused a reduction in revenues collected in the most recent full fiscal year of the recipient; Make necessary investments in water, sewer, or broadband infrastructure. Provide emergency relief from natural disasters or their negative economic impacts. Fund eligible Surface Transportation projects; and Fund Title I projects that are eligible activities under the Community Development Block Grant and Indiana Community Development Block Grant programs. As part of sound management of the federal award, the Town was responsible for implementing a system of internal controls that would ensure compliance with the applicable requirements. The Town had not properly designed or implemented such a system. There was no evidence of segregation of duties, such as an oversight, review, or approval process, that would have ensured that expenditures of award funds were made only for activities and costs that were allowable under the federal award and federal regulations and that were within the period of performance. The Town completed five transfers totaling $224,050 to the Town Utility funds. The amounts transferred to these Utility funds were commingled with other receipts; therefore, the expenditures that went with the SLFRF money, if any, could not be identified. Therefore, the $224,050 could not be tested to ensure compliance with the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. The lack of internal controls and noncompliance were isolated to the transfers noted above. Criteria 2 CFR 200.302 states in part: "(a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and programspecific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. . . . (b) The financial management system of each non-Federal entity must provide for the following . . . (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number and year, name of the Federal agency, and name of the pass-through entity, if any. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . INDIANA STATE BOARD OF ACCOUNTS 18 TOWN OF UPLAND SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. . . ." 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A proper system of internal controls was not designed by management of the Town. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the Town's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Due to the lack of internal controls, the Town was unable to differentiate expenditures made from federal and nonfederal funds once it commingled nonfederal funds and federal grant awards. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system was not effective in preventing, or detecting and correcting, material noncompliance within the grant. The Town was unable to identify all the expenditures paid with federal funds and cannot ensure, nor can we determine, expenditures of the grant were allowable activity, within the proper period, and were an allowable cost. Questioned Costs We identified $224,050 in known questioned costs as noted above in the Condition and Context. Recommendation We recommended that management of the Town establish a system of internal controls to ensure that grant award funds are accounted for and tracked in a designated grant fund. All activity of the grant should be in this fund with supporting documentation for each transaction. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2023-003 Information on the federal program: Subject: Water and Waste Disposal Systems for Rural Communities – Reporting Federal Agency: Department of Agriculture Federal Program: Water and Waste Disposal Systems for Rural Communities Assistance Listing Number: 10.760 Federal Award Numbers and Years (or Other Identifying Numbers): 2023 Compliance Requirement: Reporting Audit Findings: Significant Deficiency Criteria: 2 CFR section 200.328 states Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. Condition: The Town did not prepare or submit the required report for the grant. Cause: The Town has not developed and implemented controls over grant reporting. Effect: The Town could fail to submit required reporting to funding agency. Questioned Costs: There were no questioned costs identified. Context: The grant requires a single report, Form RD 442-3 Balance Sheet (OMB No. 0575-0015) to be filed annually. Through inquiries with management, it was determined that the Town did not prepare and review the required report. Management noted a third party came to the Town to run systems reports with the information required for the report, prepared and submitted the report on behalf of the Town. The Town did not perform a review of the report before submission by the third party. Identification as a repeat finding: No. Recommendation: We recommend that management of the Town establish a proper system of internal controls and develop and implement reporting policies and procedures that ensure timely preparation and submission of required federal reports. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Program Information: COVID-19 Governor’s Emergency Education Relief Fund (84.425C) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): In accordance with 2 CFR 200.328 and 200.329, the Organization must report financial and programmatic data as required by the terms and conditions of the Federal award. Condition: Evidence of submission could not be provided for certain reports. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The Organization was not in compliance with reporting requirements. Questioned Costs: None. Context: For 3 of 3 reports tested, we were able to confirm that the Organization submitted required reports, however, we were unable to obtain evidence that the reports were submitted by the deadline. Identification as a Repeat Finding: No similar findings were identified in the prior year. Recommendation: We recommend the Organization enhance its procedures and internal controls to ensure that records of report submission are appropriately retained. Views of Responsible Officials and Planned Corrective Actions: The Alliance will enhance its procedures and internal controls to ensure that records of report submission are appropriately retained.
Finding 2023-002: Reportable Finding Considered a Significant Deficiency – Reporting Assistance Listing Number: 10.181 Agency: U.S. Department of Agriculture Program: Pandemic Relief Activities: Farm and Food Worker Relief Program (FFWR) Award Number: AM22FFWDC0002-02 Grant Years: 2023 Criteria: The Performance and Financial Monitoring and Reporting guidelines outlined in 2 CFR sections 200.328 and 200.329 require that the Foundation submit Office of Management and Budget semi-annual financial reporting on Form SF-425. Condition: During our 2023 audit, we reviewed the Forms SF-425 submitted during the period which covered the periods November 4, 2022 through April 3, 2023 and April 4, 2023 through October 3, 2023. We reviewed the submissions for timely submission, that the reports were signed by a certifying official, and that the reports reconciled to the information obtained during the audit of the financial statements. For the SF-425 which covered the period November 4, 2022 through April 3, 2023 we could not reconcile the expenditures in the report to the underlying financial information. Cause: The Foundation did not reconcile the SF-425 to the financial records before submission. Effect: The Foundation reported erroneous amount of federal award expenditures on Form SF-425 for the period November 4, 2022 through April 3, 2023. Context: There were two SF-425 submissions during the year. Questioned Costs: There are no questioned costs associated with this finding. Repeat Finding: This is not a repeat finding. Recommendation: The Foundation should implement internal control procedures to ensure that the amounts reported in Form SF-425 are reconciled to the underlying financial records and reviewed before being signed by a certifying official and submitted. Views of Responsible Officials and Planned Corrective Actions: The views of responsible officials and planned corrective actions is included at the end of this report.
2 CFR 1000.10 gives regulatory effect to the Department of Treasury for 2 CFR part 200. 2 CFR 200.302 states, in part, the non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.302 further states, in part, the financial management system of each non-Federal entity must provide for accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. Additionally, the Ohio Department of Development (ODOD) Water and Wastewater Infrastructure Program Grant Agreement provides in paragraph 1 that “[e]xpenditures shall be supported by contracts, invoices, vouchers, and other data as appropriate, including the reports listed in accordance with the schedule set forth in Exhibit II: Reporting, evidencing the costs incurred.” For funding received directly from the Department of Treasury as an NEU, the Village did not appropriately report the correct cumulative obligations or cumulative expenditures on the April 2023 annual project and expenditure report. This caused an understatement of $17,191 in the April 2023 report. This is due to the misinterpretation of guidance provided to the Village. Failure to accurately report cumulative obligations and cumulative expenditures could result in grants being overspent. For SLFRF funding passed through the Ohio Department of Development, the Village requested reimbursements totaling $61,788 for expenditures that were paid for by funding received directly from the Department of Treasury as an NEU. This was caused due to the Village submitting incorrect invoices to the Engineering Firm. The Village identified the error and worked with ODOD to submit alternative reimbursement requests which were not paid for by other funding sources. These requests were submitted to ODOD September 12, 2024. Failure to submit correct invoices for reimbursement could result in the Village not receiving the reimbursements that it is entitled to. The Village should implement internal controls to ensure the correct amounts are included in reports submitted to the US Department of Treasury and that requests for reimbursement to ODOD only include allowable expenditures not paid by other funding sources.
2 CFR 1000.10 gives regulatory effect to the Department of Treasury for 2 CFR part 200. 2 CFR 200.302 states, in part, the non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.302 further states, in part, the financial management system of each non-Federal entity must provide for accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. Additionally, the Ohio Department of Development (ODOD) Water and Wastewater Infrastructure Program Grant Agreement provides in paragraph 1 that “[e]xpenditures shall be supported by contracts, invoices, vouchers, and other data as appropriate, including the reports listed in accordance with the schedule set forth in Exhibit II: Reporting, evidencing the costs incurred.” For funding received directly from the Department of Treasury as an NEU, the Village did not appropriately report the correct cumulative obligations or cumulative expenditures on the April 2023 annual project and expenditure report. This caused an understatement of $17,191 in the April 2023 report. This is due to the misinterpretation of guidance provided to the Village. Failure to accurately report cumulative obligations and cumulative expenditures could result in grants being overspent. For SLFRF funding passed through the Ohio Department of Development, the Village requested reimbursements totaling $61,788 for expenditures that were paid for by funding received directly from the Department of Treasury as an NEU. This was caused due to the Village submitting incorrect invoices to the Engineering Firm. The Village identified the error and worked with ODOD to submit alternative reimbursement requests which were not paid for by other funding sources. These requests were submitted to ODOD September 12, 2024. Failure to submit correct invoices for reimbursement could result in the Village not receiving the reimbursements that it is entitled to. The Village should implement internal controls to ensure the correct amounts are included in reports submitted to the US Department of Treasury and that requests for reimbursement to ODOD only include allowable expenditures not paid by other funding sources.
U.S. Department of State Professional & Cultural Exchange Programs Assistance Listing #19.415 Finding 2023-001 (repeat finding 2022-03) Material Weakness, Material Noncompliance – Reporting Criteria: The A-102 Common Rule requires that non-Federal entities receiving Federal awards establish and maintain internal control designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Adequate segregation of duties provided between performance, review, and recordkeeping of a task is a control activity which will reasonably ensure compliance with Federal laws, regulations, and program requirements. Also, 2 CFR 200.302 requires that non-federal entities must provide for the accurate, current, and complete disclosure of financial results for each Federal award or program in accordance with the reporting requirements set forth in 2 CFR section 200.328. Due dates for reporting are also explicitly noted in the grant award documents. Federal Financial Reports require the entity to report federal expenditures, cash draws, and recipients share of program costs. Condition: Internal control over federal financial reports could not be readily substantiated. Federal financial reports were not submitted timely and activity reported was not representative of actual federal expenditures for the period. Questioned Costs: None noted as amounts appear to be under reported. Context: The Flex award federal financial report was due October 31, 2023. Submission date of the Flex award federal financial report was January 17, 2024. Expense amount and cost share amount reported was not supported by underlying accounting records. The Yes award federal financial report was due October 31, 2023. Submission of the Yes award federal financial report was January 17, 2024. Expense amount and cost share amount reported was not supported by underlying accounting records. Effect: By not submitting reports timely, the Organization is not in compliance with reporting requirements and may risk losing funding. By reporting inaccurate federal expense and cost share amounts, the Organization may not be able to readily prevent, detect, and correct potential errors in reporting. Therefore, the Organization may be incorrectly reimbursed for expenditures under the program requirements. Cause: Current processes do not include a consistent method of preparing and submitting federal financial reports to ensure compliance with reporting requirements. Recommendation: The Organization should improve written policies & procedures to ensure that reports are submitted timely, ensure reports contain accurate and complete financial information related to the reporting period, and to ensure compliance with reporting requirements. Management’s Response: Management considers this finding resolved as of August 2024. In September of 2023, the prior finance manager at Greenheart left the company abruptly without notice. At the time, there were no other staff who were exposed to the grants or could complete the FFR report. Subsequently, Greenheart hired Athena Admin services to manage their finance function. The FFR reports were not filed until January 17, 2024, as Athena Admin needed time to unwind what was happening within the finance department and with the grants. Additionally, the remaining team did not have access to the portal where the filing would take place and had to take administrative steps to gain access to the portal. In 2023, as was done in prior years, there was not a multi-level approval for filing Federal Financial Reports. After the September 2023 staffing changes, the Finance Director and the Accounting Manager reviewed the FFR reports prior to filing. The Finance Director provided verbal approval to file. For all reports going forward, Greenheart will document approval of filing via email exchanges from the Accounting Manager to the Director of Finance
U.S. Department of State Professional & Cultural Exchange Programs Assistance Listing #19.415 Finding 2023-001 (repeat finding 2022-03) Material Weakness, Material Noncompliance – Reporting Criteria: The A-102 Common Rule requires that non-Federal entities receiving Federal awards establish and maintain internal control designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Adequate segregation of duties provided between performance, review, and recordkeeping of a task is a control activity which will reasonably ensure compliance with Federal laws, regulations, and program requirements. Also, 2 CFR 200.302 requires that non-federal entities must provide for the accurate, current, and complete disclosure of financial results for each Federal award or program in accordance with the reporting requirements set forth in 2 CFR section 200.328. Due dates for reporting are also explicitly noted in the grant award documents. Federal Financial Reports require the entity to report federal expenditures, cash draws, and recipients share of program costs. Condition: Internal control over federal financial reports could not be readily substantiated. Federal financial reports were not submitted timely and activity reported was not representative of actual federal expenditures for the period. Questioned Costs: None noted as amounts appear to be under reported. Context: The Flex award federal financial report was due October 31, 2023. Submission date of the Flex award federal financial report was January 17, 2024. Expense amount and cost share amount reported was not supported by underlying accounting records. The Yes award federal financial report was due October 31, 2023. Submission of the Yes award federal financial report was January 17, 2024. Expense amount and cost share amount reported was not supported by underlying accounting records. Effect: By not submitting reports timely, the Organization is not in compliance with reporting requirements and may risk losing funding. By reporting inaccurate federal expense and cost share amounts, the Organization may not be able to readily prevent, detect, and correct potential errors in reporting. Therefore, the Organization may be incorrectly reimbursed for expenditures under the program requirements. Cause: Current processes do not include a consistent method of preparing and submitting federal financial reports to ensure compliance with reporting requirements. Recommendation: The Organization should improve written policies & procedures to ensure that reports are submitted timely, ensure reports contain accurate and complete financial information related to the reporting period, and to ensure compliance with reporting requirements. Management’s Response: Management considers this finding resolved as of August 2024. In September of 2023, the prior finance manager at Greenheart left the company abruptly without notice. At the time, there were no other staff who were exposed to the grants or could complete the FFR report. Subsequently, Greenheart hired Athena Admin services to manage their finance function. The FFR reports were not filed until January 17, 2024, as Athena Admin needed time to unwind what was happening within the finance department and with the grants. Additionally, the remaining team did not have access to the portal where the filing would take place and had to take administrative steps to gain access to the portal. In 2023, as was done in prior years, there was not a multi-level approval for filing Federal Financial Reports. After the September 2023 staffing changes, the Finance Director and the Accounting Manager reviewed the FFR reports prior to filing. The Finance Director provided verbal approval to file. For all reports going forward, Greenheart will document approval of filing via email exchanges from the Accounting Manager to the Director of Finance
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.328 and 2 CFR 200.329 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with the program requirements. Condition: Of three reports tested, two instances in which support was not retained to substantiate federal share of expenditures reported in a quarterly report and the final report. Management subsequently worked to reconcile reports out of the Organization’s accounting software to support federal expenditures reported within the reports that materially agree. Additionally, individual who prepared the report is the same individual approving the report prior to submission to the federal agency. Cause: Support was not retained to substantiate amounts reported within a semi-annual report and final report. Additionally, management hasn’t implemented controls ensuring the individual preparing the report is separate from the individual who reviews and approves the report prior to submission to the federal agency. Effect: Without retaining documentation to support the amounts reported, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Additionally, not having a formal oversight process over reporting results in a reasonable possibility that reports that are inaccurate or incomplete could be submitted. Questioned Costs: None reported. Context/Sampling: Two out of four semi-annual financial reports were reviewed along with one annual financial report. There was a total of five financial reports filed. Repeat Finding from Prior Year: No.
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Reporting Federal Agency: Department of Treasury Criteria: Under the requirements of 2 CFR 200.328 and 31 CFR section 35.4(c). 170, performance reports should include various data including current period expenditures. Condition: The County’s first quarter 2023 performance report incorrectly included expenditures that were incurred throughout fiscal year 2022. Questioned Costs: N/A Context: Two of the County’s four reports were initially selected for testing under the program. The County incorrectly included 2022 expenditures in the first quarter report. Effect: The County did not report the expenditures in the proper period as required. Cause: The County did not have adequate controls or procedures in place to identify the applicable reporting requirement and ensure the information was filed accurately and timely. Identification as a Repeat Finding: N/A Recommendation: Management should implement policies and procedures to ensure required reports are completed accurately and filed by their respective due dates as required by the grant agreement and Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: We agree with the finding. See separate report for planned corrective actions.
2 CFR § 1201.1 except as otherwise provided in this part, the Department of Transportation adopts the Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200). 2 CFR § 200.328 states unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead). This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. The District’s grant agreement states on or before the 20th day of the first month of each quarter and until the budget period end date of December 31, 2026, the Recipient shall submit to the U.S. Department of Transportation (USDOT) a Quarterly Project Progress Report and Recertification. During testing we noted four out of four (100%) of the District’s quarterly reports were submitted to USDOT with the incorrect expenditures, report period or grant period. Due to the deficient internal control structure, elements of the reporting requirements were not properly submitted during Fiscal Year 2023. Failure to properly submit quarterly reports could result in ODOT taking action against the District for failure to comply with programmatic requirements. The District should implement policies and procedures to review the reports prior to submission to ODOT, to help ensure the reports are complete and accurate.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreements for the Village of Lafayette Water Line Project (B-W-20-1AB-1), Village of Harrod Water Line Project (B-W-20-1AB-2), the Gomer Wastewater Collection System Project (B-W-20-1AB-3), Community Development Program B-F-20-1AB-1, Community Development Block Grant B-F-22-1AB-1 and (Community Housing Impact and Preservation Program) B-C-21-1AB-1, state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), two out of eight (twenty-five percent) Status Reports were submitted between five to twelve months late. For one out of eight (twelve percent) Status Reports the reported expenditures were $4,386 more than the supporting accounting records (see related finding number 2023-002). Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
2 C.F.R. § 200.328 states, in part, this information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Mental Health and Recovery Board of Portage County failed to submit the final expenditures report to the Ohio Department of Mental Health and Addiction Services for both awards under the State Opioid Response Grant Program. The reports were subsequently filed on October 21, 2024, 342 days after the required due date. This is the result of the County not having effective internal controls over reporting requirements. Noncompliance with grant requirements could have an adverse effect on future grant awards by the awarding agency. The County did not have effective internal controls to help ensure that all reporting requirements were met as required by the grant agreement. The lack of internal controls could result in the County failing to track grants appropriately, as well as, submitting late and/or inaccurate reports leading to further noncompliance.
2 C.F.R. § 200.328 states, in part, this information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Mental Health and Recovery Board of Portage County failed to submit the final expenditures report to the Ohio Department of Mental Health and Addiction Services for both awards under the State Opioid Response Grant Program. The reports were subsequently filed on October 21, 2024, 342 days after the required due date. This is the result of the County not having effective internal controls over reporting requirements. Noncompliance with grant requirements could have an adverse effect on future grant awards by the awarding agency. The County did not have effective internal controls to help ensure that all reporting requirements were met as required by the grant agreement. The lack of internal controls could result in the County failing to track grants appropriately, as well as, submitting late and/or inaccurate reports leading to further noncompliance.
FINDING 2023-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, and Procurement and Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): PO 20011717 Pass-Through Entity: Indiana State Department of Health Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context The County Department of Health, a department within the County, was awarded the Health Issues and Challenges grant through the Indiana State Department of Health financed through the American Rescue Plan Act for the purpose of funding programs that focus on the improvement of chronic disease, specifically, elevated blood lead level reduction. The Health Issues and Challenges grant is a reimbursable grant, whereby the County received reimbursement on a per-case basis at a stated rate for Case Management and Environmental Investigation activities performed. The County Department of Health received federal receipts related to the grant in the amount of $130,479 during 2023. As part of sound management of the federal award, the County Department of Health was responsible for implementing a system of internal controls that would ensure compliance with the applicable requirements. The County Department of Health did not properly design or implement such a system. Receipts of the program were adequately identified through the use of an account number within the County Health Fund (285) in the County's ledger (ledger) which was unique to the Health Issues and Challenges grant receipts. However, the ledger did not adequately identify the expenditures of the grant program within the County Health Fund. Through inquiry with the County Department of Health employees and review of unit-prepared support of grant expenditures, we determined expenditures were made with grant funds during the audit period; however, we were unable to distinguish between the expenditures of the Health Issues and Challenges grant and all other activities of the County Department of Health in the County Health fund. Due to the lack of separate identification of expenditures in the financial records, we were not able to establish a population from which to audit the Health Issues and Challenges grant for compliance with the following compliance requirements of the program: Activities Allowed or Unallowed Allowable Costs/Cost Principles Period of Performance Procurement and Suspension and Debarment As such, the full award amount of $130,479, as reported on the Schedule of Expenditures of Federal Awards, was determined to be questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.300(b) states in part: "The non-Federal entity is responsible for complying with all requirements of the Federal award. . . ." 2 CFR 200.302 states in part: "(a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. . . . (b) The financial management system of each non-Federal entity must provide for the following . . . (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number and year, name of the Federal agency, and name of the pass-through entity, if any. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. . . ." Cause The County Department of Health was unable to differentiate expenditures made from federal and non-federal funds within its ledger for the Heath Issues and Challenges grant. Effect Without the proper implementation of an effectively designed system of internal controls, a population of expenditures associated with the Health Issues and Challenges grant could not be determined. As such, the County Department of Health cannot ensure nor can we determine that expenditures of the grant were not unallowable, within the proper period, and adhered to established practices and policies. Questioned Costs We identified $130,479 in known questioned costs as noted in the Condition and Context. Recommendation We recommended that management of the County Department of Health establish a system of internal controls to ensure that grant award funds are adequately accounted for and tracked in such a manner as to determine the activity, receipts, and disbursements associated with the grant. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Agency U.S. Department of Transportation, Federal Motor Carrier Safety Administration ALN 20.232 Commercial Driver’s License Program Implementation Federal Award Identification Number 69A3601940354CDL0NV, 69A3602040472CDL0NV 69A3602140719CDL0NV 69A3602240864CDL0NV Criteria According to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 200.327 and 200.328, recipients of federal awards are required to submit performance and financial reports by the due dates specified in the terms and conditions of the federal award. Condition and Context We sampled and tested eight reports and four of the eight selected reports were not submitted within the specified reporting dates. Cause The College failed to maintain a system of controls and procedures to ensure that the various reports were submitted within the required reporting timeframes. Effect Failure to submit required reports within the required dates may result in The College being noncompliant with 2 CFR 200.327 & 328. Repeat Finding No Recommendation We recommend The College review its controls and procedures to ensure that all its reporting requirements are being adhered to and the reports are being submitted with the specified filing dates.
2 CFR § 1201.1 except as otherwise provided in this part, the Department of Transportation adopts the Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200). 2 CFR § 200.328 states unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead). This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. The District’s grant agreement states on or before the 20th day of the first month of each quarter and until the budget period end date of December 31, 2026, the Recipient shall submit to the U.S. Department of Transportation (USDOT) a Quarterly Project Progress Report and Recertification. During testing we noted four out of four (100%) of the District’s quarterly reports were submitted to USDOT with the incorrect expenditures, report period or grant period. Due to the deficient internal control structure, elements of the reporting requirements were not properly submitted during Fiscal Year 2023. Failure to properly submit quarterly reports could result in ODOT taking action against the District for failure to comply with programmatic requirements. The District should implement policies and procedures to review the reports prior to submission to ODOT, to help ensure the reports are complete and accurate.
FINDING 2023-004 Subject: Water and Waste Disposal System for Rual Communities - Reporting Federal Agency: Department of Agriculture Federal Program: Water and Waste Disposal System for Rural Communities Assistance Listings Number: 10.760 Federal Award Number and Year (or Other Identifying Number): CY 2023 Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The Town had not designed or implemented adequate internal controls and procedures to ensure that reports were prepared, accurate, and submitted in accordance with the applicable compliance requirements for the federal grant. The United States Department of Agriculture (USDA) requires the following reports be submitted annually: Statement of Budget, Income, and Equity (Form RD 442-2) Balance Sheet (Form RD 442-3) The Form RD 442-2 covers financial operations relating to the Town's water main replacement project and the Form RD 442-3 presents the financial status of the project. In both instances, a borrower may submit the financial data on other forms, provided the forms are in a similar format and signed and dated by the organization's official to certify the correctness of the information. Alternatively, an annual audit may be submitted in lieu of the forms. The Town was required to file each report, as noted above, during the audit period; however, the reports were not filed. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 19 TOWN OF LAFONTAINE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 7 CFR 1780.47 states in part: "Borrower accounting methods, management reporting and audits. . . . (e) Borrowers exempt from audits. All borrowers who are exempt from audits, will, within 60 days following the end of each fiscal year, furnish the RUS with annual financial statements, consisting of a verification of the organization's balance sheet and statement of income and expense by an appropriate official of the organization. Forms RD 442-2, 'Statement of Budget, Income and Equity,' and 442-3 may be used. (f) Management reports. These reports will furnish management with a means of evaluating prior decisions and serve as a basis for planning future operations and financial strategies. In those cases where revenues from multiple sources are pledged as security for an RUS loan, two reports will be required; one for the project being financed by RUS and one combining the entire operation of the borrower. In those cases where RUS loans are secured by general obligation bonds or assessments and the borrower combines revenues from all sources, one management report combining all such revenues is acceptable. The following management data will be submitted by the borrower to the processing office. These reports at a minimum will include a balance sheet and income and expense statement. . . . (2) Annual management reports. Prior to the beginning of each fiscal year the following will be submitted to the processing office. (If Form RD 442-2 is used as the annual management report, enter data in column three only of Schedule 1, and complete all of Schedule 2.) (i) Two copies of the management reports and proposed 'Annual Budget'. (ii) Financial information may be reported on Form RD 442-2 which includes Schedule 1, 'Statement of Budget, Income and Equity' and Schedule 2, 'Projected Cash Flow' or information in similar format. (iii) A copy of the rate schedule in effect at the time of submission. INDIANA STATE BOARD OF ACCOUNTS 20 TOWN OF LAFONTAINE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (g) Substitute for management reports. When RUS loans are secured by the general obligation of the public body or tax assessments which total 100 percent of the debt service requirements, the State program official may authorize an annual audit to substitute for other management reports if the audit is received within nine months after the end of the audit period." Cause The Town incorrectly assumed that the reports were filed by the engineering firm coordinating the grant. Effect Without the proper implementation of an effectively designed system of internal controls, the Town cannot ensure the required reports are filed with the awarding agency. As such, the USDA does not have accurate and current information to discern the financial status of the Town's project. Furthermore, noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the Town. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Town's management design and implement a system of internal controls to ensure that all required reports are filed. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
31 CFR § 35.4(c) requires, in part, recipients, during the period of performance, to provide the Secretary of the U.S. Department of Treasury periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. 2 CFR 1000.10 provides that, except for the deviations set forth elsewhere in this Part, the Department of Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards set forth at 2 CFR Part 200. 2 CFR 200.302(b) states, in part, that the financial management system of each non-Federal entity must provide for the accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. The County was required to submit a Project and Expenditure Report by October 31, 2023, to the U.S Department of the Treasury through the Treasury’s Portal. However, the lack of adequate control procedures in place for reporting resulted in the County omitting $2,000,851 in expenditures that were reported on their 2023 Schedule of Expenditures of Federal Awards from their 2023 third quarter Project and Expenditure Report. We also noted the County submitted the 2023 fourth quarter Project and Expenditure Report on March 7, 2024 instead of the required date of January 31 2024. The County should establish a proper control process over reporting to ensure the timely, complete, and accurate submission of the Project and Expenditure Reports. This will help reduce the risk of Treasury taking action against the County for failure to comply with programmatic requirements.
31 CFR § 35.4(c) requires, in part, recipients, during the period of performance, to provide the Secretary of the U.S. Department of Treasury periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. 2 CFR 1000.10 provides that, except for the deviations set forth elsewhere in this Part, the Department of Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards set forth at 2 CFR Part 200. 2 CFR 200.302(b) states, in part, that the financial management system of each non-Federal entity must provide for the accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. The County was required to submit a Project and Expenditure Report by October 31, 2023, to the U.S Department of the Treasury through the Treasury’s Portal. However, the lack of adequate control procedures in place for reporting resulted in the County omitting $2,000,851 in expenditures that were reported on their 2023 Schedule of Expenditures of Federal Awards from their 2023 third quarter Project and Expenditure Report. We also noted the County submitted the 2023 fourth quarter Project and Expenditure Report on March 7, 2024 instead of the required date of January 31 2024. The County should establish a proper control process over reporting to ensure the timely, complete, and accurate submission of the Project and Expenditure Reports. This will help reduce the risk of Treasury taking action against the County for failure to comply with programmatic requirements.
1. Reporting Finding Number: 2023-002 Assistance Listing Number and Title: AL # 21.027 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Treasury Compliance Requirement: Reporting Pass-Through Entity: N/A Repeat Finding from Prior Audit? No Material Weakness and Noncompliance 2 CFR § 1000.10 gives regulatory effect to Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200 for the Department of Treasury. 2 CFR 200.328 (b) provides that The Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports. 31 CFR 35.4(c) requires recipients, in part, during the period of performance, to provide the Secretary of the U.S. Department of Treasury periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. The U.S. Department of Treasury provided supplementary information on reporting requirements in its interim final rule for State and Local Fiscal Recovery Funds for 31 CFR Part 35 and provided further guidance in its Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guide. Metropolitan cities and counties with a population below 250,000 residents that are allocated less than $10 million in SLFRF funding, and NEUs that are allocated less than $10 million in SLFRF funding are required to submit Project and Expenditure Report by April 30, 2022, and then annually thereafter. The County submitted the required Project and Expenditure Report on April 10, 2023, which is within the required timeframe. However, due to the failure of existing controls, the expenditures reported did not agree to the accounting records due to $1,210,069 identified as loss of revenue being excluded from Project and Expenditure Report. Reporting errors could adversely affect future grant awards. Additional controls should be implemented to help ensure accuracy of the reports. Officials’ Response: See Corrective Action Plan.
1. Reporting Finding Number: 2023-002 Assistance Listing Number and Title: AL # 21.027 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Treasury Compliance Requirement: Reporting Pass-Through Entity: N/A Repeat Finding from Prior Audit? No Material Weakness and Noncompliance 2 CFR § 1000.10 gives regulatory effect to Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200 for the Department of Treasury. 2 CFR 200.328 (b) provides that The Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports. 31 CFR 35.4(c) requires recipients, in part, during the period of performance, to provide the Secretary of the U.S. Department of Treasury periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. The U.S. Department of Treasury provided supplementary information on reporting requirements in its interim final rule for State and Local Fiscal Recovery Funds for 31 CFR Part 35 and provided further guidance in its Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guide. Metropolitan cities and counties with a population below 250,000 residents that are allocated less than $10 million in SLFRF funding, and NEUs that are allocated less than $10 million in SLFRF funding are required to submit Project and Expenditure Report by April 30, 2022, and then annually thereafter. The County submitted the required Project and Expenditure Report on April 10, 2023, which is within the required timeframe. However, due to the failure of existing controls, the expenditures reported did not agree to the accounting records due to $1,210,069 identified as loss of revenue being excluded from Project and Expenditure Report. Reporting errors could adversely affect future grant awards. Additional controls should be implemented to help ensure accuracy of the reports. Officials’ Response: See Corrective Action Plan.