Federal agency: Federal Aviation Administration Federal program title: Airport Improvement Program Assistance Listing Number: 20.106 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Federal Aviation Administration (FAA) guidelines require Airport Improvement Program recipients to submit periodic financial reports, including SF-425 (Federal Financial Report), Form 5100- 127 (Operating and Financial Summary), Form 5100-126 (Financial Government Payment Report), Form 5370-1 (Construction Progress and Inspection Report), and Form SF-271 (Requests for Reimbursement) in accordance with 2 CFR §200.328 and §200.329. Condition: During our testing, we noted that for each of the County’s seven Airport Improvement Program grants, only Form SF-271 was submitted for the audit period, despite requirements to submit five distinct report types per grant. Questioned costs: None Context: We initially sampled 31 of 105 reports required to be submitted during the year by the granting agency. 11 of the 11 SF-271 reports were received from the county and tested without exception. The department explained that Forms SF-425, 5100-127, 5100-126, and 5370-1 had not been submitted for the year under audit and therefore could not be provided. Cause: The aviation department was previously not aware of the reporting requirements of the grant. When the department became aware of the requirements they began working with the FAA to ensure all required reports were submitted. The delay in becoming aware of these requirements resulted in a significant backlog to be submitted which was exacerbated by understaffing at the department. Effect: The County’s failure to submit four of the five required reports for each of its seven Airport Improvement Program grants resulted in noncompliance with FAA reporting requirements under 2 CFR §200.328 and §200.329. This lack of reporting may impact the County’s ability to demonstrate proper stewardship of federal funds, delay reimbursement processing, and potentially affect future grant eligibility or funding decisions. Repeat Finding: This is not a repeat finding. Recommendation: CLA recommends that the County provide staff with training related to identifying and complying with grant requirements. Additionally, CLA recommends that the County implement tracking procedures, such as a monitoring checklist, to ensure all required reports are submitted in a timely manner. Views of responsible officials: There is no disagreement with the audit finding.
Finding: 2024-003 Timely Financial and Programmatic Reporting (Significant Deficiency) Information on the Federal Programs: ALN #10.937 Partnerships for Climate-Smart Commodities Criteria or Specific Requirement (including Statutory, Regulatory, or Other Citation): Per 2 CFR 200.328(b)(1), recipients must submit financial reports at intervals required by the Federal awarding agency, but no less frequently than annually and no more frequently than quarterly. Reports must be submitted no later than 30 calendar days after the reporting period end date. Per 2 CFR 200.329(b), recipients are required to submit performance reports at intervals required by the Federal awarding agency, but no less frequently than annually and no more frequently than quarterly. Performance reports must also be submitted no later than 30 calendar days after the reporting period end date.Condition: During our testing of quarterly reporting requirements, we noted the following: Financial Reports: Four of four (100%) quarterly financial reports were submitted after the 30-day deadline. Performance Reports: Three of four (75%) quarterly performance reports were submitted after the 30-day deadline. Detailed Progress Reports: CIF was unable to provide evidence of submission (such as electronic confirmation or date-stamped copies). As a result, we were unable to determine whether these reports were submitted timely. Cause: These issues occurred due to delays in internal review processes and the absence of a robust tracking system for reporting deadlines. Additionally, documentation supporting the submission of the detailed progress reports was not retained. Effect or Potential Effect: Untimely submission of required reports limits the Federal awarding agency’s ability to evaluate financial and program performance in a timely manner. The lack of submission documentation for detailed progress reports also creates a risk that required reports may not be submitted at all, which could impact continued funding, create compliance findings, and impair the Federal awarding agency’s oversight responsibilities. Questioned Costs: N/A Context: Our testing included 100% of required quarterly reports for the audit period. We identified late submission for 100% of financial reports and 75% of performance reports. For detailed progress reports, no documentation was available to confirm submission for the entire period reviewed. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management: 1. Implement controls, such as a reporting calendar with automated reminders, to ensure that financial and performance reports are prepared, reviewed, and submitted within 30 days of the quarter-end, in compliance with 2 CFR 200.328(b)(1) and 2 CFR 200.329(b). 2. Retain submission confirmations for all reports, including detailed progress reports, to provide an audit trail and evidence of compliance with Federal requirements.
2024-007 U.S. Department of Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – ALN 21.027 Significant Deficiency in Internal Controls over Compliance and Compliance Finding Criteria: Per 2 CFR section 200.328 of the Uniform Guidance, each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the federal agency. The compliance supplement identified four Key Line Items required to be reported to the federal awarding agency which include (1) current period obligation, (2) cumulative obligation, (3) current period expenditure and (4) cumulative expenditure. Condition: As of the March 31, 2024 reporting date, the Town’s Project and Expenditure report had reported cumulative expenditures that were approximately $29,900 less than what was recorded in the grant fund on the general ledger. Cause: The Town did not reconcile the Project and Expenditure report with the Town’s general ledger before submitting. Effect: The Town did not properly report grant expenditures in the Project and Expenditure reporting. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2023-008 Recommendation: The Town should implement procedures to reconcile the financial information in the Project and Expenditure reports to the Town’s general ledger before submission. Views of Responsible Official: Management agrees with the finding.
FINDING 2024-014 Subject: Title I Grants to Local Educational Agencies - Reporting Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-014. Condition and Context The system of internal controls over the applicable reports, as established by the School Corporation, was not properly implemented nor was it operating effectively to ensure that sufficient audit evidence was maintained to support the requests for reimbursement, as well as the Final Expenditure Reports submitted by the School Corporation. The Title I Director approved the requests for reimbursement and the Final Expenditure Reports prior to submission; however, this review was not effective. The fiscal years 2021-2022 and 2022-2023 Final Expenditure Reports and the six reimbursement requests were selected for testing. The School Corporation was unable to provide for audit documentation to support the underlying data accumulated and summarized in each of the Financial Expenditure Reports or the six reimbursement requests. The reported data could not be traced to records that accumulate or summarize the data; therefore, the accuracy and completeness of the reports could not be verified. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 47 NORTH LAWRENCE COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 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. . . . (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. . . ." 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." Cause Due to turnover of staffing in the School Corporation's administrative office, the School Corporation's management had not designed nor implemented a system of internal controls that would have ensured compliance or that supporting documentation would have been maintained and available for audit related to the Reporting compliance requirement. Effect Without a proper system of internal controls in place that operated effectively, the School Corporation did not retain and provide appropriate supporting documentation. This prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure documentation will be maintained and made available for audit as related to the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Federal Program American Rescue Plan Act, Assistance Listing No. 21.027 Criteria Per U.S. Treasury American Rescue Plan Act reporting requirements and 2 CFR §200.328, recipients are required to submit complete and accurate Project and Expenditure reports in a timely manner as prescribed by the grantor. Condition The entity did not submit the required Project and Expenditure report for the American Rescue Plan Act program by the applicable federal due date. Cause The entity did not have a formal process or monitoring control in place to ensure American Rescue Plan Act Project and Expenditure reporting deadlines were identified, tracked, and met. Effect Failure to submit Project and Expenditure reports timely may result in delayed reimbursements, increased risk of noncompliance with federal requirements, potential questioned costs, and could negatively impact future ARPA funding or other federal grant awards. Questioned Costs None. Recommendation We recommend the City implement internal controls to perform a timely closing of the audit, which would include the preparation of the schedule of expenditures of federal awards. This would allow for the timely submission of required report to the federal government. Repeat Finding Not repeating. Managements Response See Corrective Action Plan.
2024-008 Federal Agencies: U.S. Department of Agriculture Federal Program Names: The Child Nutrition Cluster: National School Lunch Program Summer Food Service Program Assistance Listing Numbers: 10.555 10.559 Pass-Through Agency: Commonwealth of Pennsylvania, Department of Education Pass-Through Number: 359-46-477-8 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria: Uniform Guidance requires recipients to submit accurate, complete, and timely financial and performance reports for federal awards (2 CFR 200.327 and 200.328). Program specific reporting instructions for the Child Nutrition Cluster require the FNS 10 and FNS 418 to be filed within 30 days after month end. Condition: As part of the reporting requirements for the CBS Food Program under the National School Lunch Program (NSLP) and Summer Food Service Program (SFSP), management is responsible for submitting the FNS 10 (NSLP) and FNS 418 (SFSP) reports within 30 days after month-end. However, management was unable to provide five (5) monthly NSLP reports and one (1) monthly SFSP report requested for audit testing. Questioned Costs: None Cause: Management did not maintain adequate internal controls to ensure that required monthly program reports were properly completed, retained, and available for audit. This may include weaknesses in recordkeeping processes, staff turnover, or insufficient monitoring of reporting deadlines. Effect: Failure to maintain and provide required federal reports results in noncompliance with federal reporting requirements. Because key source documents were unavailable, auditors were unable to verify the accuracy, completeness, and timeliness of reported program activity for those months. This increases the risk of misreporting or unsupported claims being submitted to the federal government. Recommendation: The Organization should establish and enforce strengthened internal controls over federal reporting to ensure that all required monthly reports (FNS 10 and FNS 418) are: (a) completed accurately, (b) submitted on time, and (c) retained in accordance with federal record retention requirements (2 CFR 200.334). Management should designate responsible personnel and implement a monitoring process to ensure compliance. Views of Responsible Officers and Corrective Action Plan: Please refer to Community Benefit Solutions dba CBS Food Program’s Corrective Action Plan
Finding 2024-006 – Compliance; Internal Control over Compliance, Reporting (Material Weakness) Name of Federal Agency: U.S. Environmental Protection Agency Federal Program Name: Nonpoint Source Implementation Grants Assistance Listing Numbers: 66.460 Pass-Through Entity: Oregon Department of Environmental Quality Name of Federal Agency: U.S. Department of Commerce – National Oceanic and Atmospheric Administration Federal Program Name: Pacific Coast Salmon Recovery Program Assistance Listing Numbers: 11.438, 15.015, 15.244 Pass-Through Entity: State of Oregon – Oregon Watershed Enhancement Board (OWEB) Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: National Fish and Wildlife Foundation Assistance Listing Numbers: 10.665 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of AgricultureFederal Program Name: Natural Resources Conservation Service Assistance Listing Numbers: 10.905 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Wildlife, Sport Fish and Restoration Program Assistance Listing Numbers: 15.244 Pass-Through Entity: Bureau of Land Management Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Secure Rural Schools and community Self-Determination – Watershed and water-quality improvements Assistance Listing Numbers: 15.234 Pass-Through Entity: Bureau of Land Management Criteria: Under 2 CFR 200, recipients must submit performance and financial reports as required by the terms and conditions of the award and must retain records sufficient to demonstrate compliance (see (§200.301Monitoring and reporting program performance, and §200.328 Financial reporting, §200.329 Monitoring and reporting program performance, and §200.334 Retention requirements for records). The grant agreements for awards above require timely submission of performance / progress reports by specified due dates, with documentation maintained to support the submitted information. Condition: For the fiscal year ended June 30, 2024, the auditee could not provide sufficient evidence that required reports for the programs listed were prepared, reviewed, and submitted in accordance with grant terms. Specifically: No provided required financial reports, and Partnership for the Umpqua Rivers lacked copies or evidence of submission, and support for reported amounts requested. Auditors were not provided with performance/progress reports and were instructed that Partnership for the Umpqua Rivers had no retained copies, review sign-offs, or submission confirmation. Where payments were received, support for the required reports or metrics were not retained and could not be supplied to auditors for reconciling to underlying records. Cause: Management has not implemented formal reporting controls, including: A documented reporting calendar with due dates and responsible staff, Reconciliation of report amounts to the accounting records, Retention procedures for report copies, underlying support, and submission confirmations, and Supervisory review evidenced by signatures or workflow approvals. Effect or Potential Effect: Absent evidence of timely, accurate reporting and adequate record retention: The organization is at risk of noncompliance with federal award conditions, Inaccurate financial or performance information may be reported to the funding agency, and The entity may be subject to remedial actions, including heightened monitoring, repayment of questioned amounts, or potential suspension of funding. Questioned Cost: None directly noted, but potential risk if reports were incomplete or inaccurate.Context: During our audit, it was found that the Partnership for the Umpqua Rivers experienced complete staff turnover in Financial Management for the year being audited. No current finance employees had worked for the organization during the year being audited. Award files provided to auditors did not contain information related to reporting of activity, expenditures, or progress of the awards. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit. Recommendation: We recommend that Partnership for the Umpqua Rivers: Establish a formal reporting and retention policy aligned with 2 CFR 200 and grant terms. Implement a centralized reporting calendar that tracks due dates, preparers, reviewers, and submission methods. Require reconciliations of financial reports to the general ledger and supporting schedules, retain the reconciliation with the reporting package. Create standard workpapers for performance metrics for each award. Configure the grant portal or document management system to retain submission confirmations, reports, receipts, and version -controlled copies of all reports for awards. Document supervisory review through sign-offs prior to submission and with evidence retained. Provide training to staff on Uniform Guidance requirements and record retention (§200.334). District Response: Partnership for the Umpqua Rivers acknowledges the deficiencies. Corrective Action Plan: ____________ (To be completed by Partnership for the Umpqua Rivers) Planned Implementation Date: _____________ Responsible Person: Partnership for the Umpqua Rivers Finance Manager
Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-through Agency: Northampton County Pass-Through Number: N/A Award Period: May 18, 2022 - December 31, 2025; October 1, 2022 - December 31, 2025 May 18, 2023 - December 31, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: Uniform Guidance requires recipients to prepare, submit, and retain accurate, complete, and timely financial reports for federal awards in accordance with 2 CFR §§ 200.327 and 200.328. Additionally, federal record retention requirements (2 CFR § 200.334) require organizations to maintain supporting documentation sufficient to substantiate reported program activity. Condition: During audit testing of financial reporting for the Coronavirus State and Local Fiscal Recovery Funds program, the Organization was unable to locate three of ten financial reports requested for review. As a result, auditors were unable to verify the accuracy, completeness, or timeliness of the reported financial information for those reporting periods. Questioned Costs: None. Context: Ten reports were requested for audit testing and management was unable to provide three of the requested reports. Cause: The Organization experienced turnover within the finance department, which contributed to inadequate document retention and weaknesses in controls over the preparation and maintenance of required financial reports. Effect: Failure to maintain and provide required financial reports constitutes noncompliance with federal reporting and record retention requirements. The absence of key source documentation limits assurance that reported program activity is accurate and supported and increases the risk of misreporting or unsupported claims being submitted to the federal government. Repeat Finding: N/A: Not a repeat finding Recommendation: The Organization should strengthen internal controls over financial reporting and record retention by establishing clear procedures to ensure that all required reports are accurately prepared, timely submitted, and retained in accordance with federal requirements. Management should designate responsible personnel and implement monitoring procedures to verify compliance with reporting and documentation standards. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries’ Corrective Action Plan.
U.S. Department of Environmental Protection Agency Passed through State Department of Natural Resources and Conservation FFAL# 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Reporting Material Non-compliance Material Weakness in Internal Control Criteria: • 2 CFR §200.303 requires non-federal entities to establish and maintain effective internal control over federal awards. • 2 CFR §200.328 requires recipients to submit accurate financial reports and maintain records that support the data reported. Condition: The District does not have documented internal controls over the preparation and review of federal financial reports. During our testing, we noted: • For one quarterly report, the District used an incorrect reporting period. • For both sampled reports, the District did not maintain the required supporting documentation in the reporting package to substantiate the amounts reported to the cognizant agency. Cause: The District has not implemented documented internal controls over the reporting process and did not ensure that supporting documentation was retained for amounts reported. Effect: Failure to maintain accurate reporting and supporting documentation increases the risk of noncompliance with Uniform Guidance and may result in questioned costs or misreporting to the cognizant agency. Questioned Costs: None to report. Context/Sampling: A nonstatistical sample of two reports were selected for testing. Repeat Finding from Prior Years: No. Recommendation: We recommend the District: • Develop and implement documented internal controls over the reporting process, including review procedures to ensure accuracy of reporting periods. • Maintain complete supporting documentation in the reporting package for all amounts reported to the cognizant agency. • Provide training to staff responsible for preparing and reviewing reports to ensure compliance with Uniform Guidance requirements. Views of Responsible Officials: Agree.
FINDING NUMBER 2024-002 REQUIREMENT REPORTING TYPE OF FINDING MATERIAL WEAKNESS FEDERAL PROGRAM 14.871 – SECTION 8 HOUSING CHOICE VOUCHERS CONDITION The Municipality did not submit or file the required FASS PH financial report for the fiscal year ended June 30, 2024. At the completion of the audit, the report remained outstanding and had not been uploaded to the FASS PH system, resulting in noncompliance with HUD’s reporting requirements. CRITERIA Entities administering the Section 8 Housing Choice Voucher Program (AL 14.871) must submit annual financial information to the U.S. Department of Housing and Urban Development (HUD) through the Financial Assessment Subsystem – Public Housing (FASS PH). This requirement is established under: • 2 CFR 200.327–200.328 (Uniform Guidance reporting requirements) • HUD Uniform Financial Reporting Standards (UFRS) • HUD Public Housing Assessment System (PHAS) – FASS PH requirements • Applicable HUD notices and guidance for FY 2024 These regulations require timely submission of complete and accurate financial data to allow HUD to evaluate the financial condition and compliance performance of the Municipality’s Housing Choice Voucher Program. CAUSE The failure to submit the FASS PH report resulted from insufficient internal controls over the financial reporting process. Contributing factors included: • Lack of a formal monitoring process to track HUD reporting deadlines • Inadequate supervisory review of required submissions • Limited staff knowledge of HUD’s UFRS and FASS PH reporting procedures EFFECT Non-compliance may result in HUD administrative actions, negative impact on the municipality’s financial assessment score, delays or interruptions in federal funding and potential for increased oversight or monitoring by HUD. QUESTIONED COST None RECOMMENDATION The municipality should establish and document formal internal controls to ensure timely preparation and submission of the FASS PH report. Assign responsibility to specific personnel and implement a compliance calendar for HUD reporting deadlines. Provide training to financial staff on HUD reporting requirements, UFRS, and the FASS PH system. Implement a supervisory review process to verify completeness and accuracy before submission. Submit the outstanding FASS PH report as soon as possible, if HUD still permits late filing. PRIOR YEAR FINDING None VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION The Municipality of Comerío made a contract with an auditing firm to work on the reports and submission of the FASS-PH financial report compliance for the years in which the reports were not submitted. Furthermore, instructions were given for the HUD Coordinator to monitor the delivery of reports by the contracted auditing firm and to ensure that the contract for this service is finalized. Personnel in charge: Brenda L. Reyes Rivera, HUD Coordinator Compliance period: April 30, 2026
Department of Transportation Federal Financial Assistance Listing 20.106; Awards AIP3‐46‐0050‐54, AIP3‐46‐0050‐59, AIP3‐46‐0050‐60, and AIP3‐46‐0050‐62. COVID‐19 Airport Improvement Program Reporting Significant Deficiency in Internal Control over Compliance Criteria ‐ 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award. 2 CFR 200.327 and 2 CFR 200.328 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 ‐ The SF‐425 annual report dated September 30, 2023, for award AIP3‐46‐0050‐54 underreported the federal share of expenditures by $80,133, while the FAA Form 5100‐127 annual report dated December 31, 2022, for all awards underreported the externally restricted assets by $397,646. Cause ‐ The Authority does not have an internal control structure designed to ensure amounts reported on SF‐425 and FAA Form 5100‐127 reports are adequately reviewed and agree to underlying accounting records. Effect ‐ Lack of compliance with designed internal controls over reporting could result in the Authority reporting incorrect or incomplete information. Questioned Costs ‐ None reported. Context/Sampling ‐ A nonstatistical sample of 10 reports out of 31 reports. Repeat Finding from Prior Year – Yes, prior year finding 2022‐002 Recommendation ‐ Management should determine and formalize reporting responsibilities between the Airport and the State and establish review processes to ensure that amounts included in SF‐425 and FAA Form 5100‐127 reports agree with the underlying accounting records. Views of Responsible Officials ‐ Management agrees with the finding.
Department of Transportation Federal Financial Assistance Listing 20.106; Awards AIP3‐46‐0050‐54, AIP3‐46‐0050‐59, AIP3‐46‐0050‐60, and AIP3‐46‐0050‐62. COVID‐19 Airport Improvement Program Reporting Significant Deficiency in Internal Control over Compliance Criteria ‐ 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award. 2 CFR 200.327 and 2 CFR 200.328 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 ‐ The SF‐425 annual report dated September 30, 2023, for award AIP3‐46‐0050‐54 underreported the federal share of expenditures by $80,133, while the FAA Form 5100‐127 annual report dated December 31, 2022, for all awards underreported the externally restricted assets by $397,646. Cause ‐ The Authority does not have an internal control structure designed to ensure amounts reported on SF‐425 and FAA Form 5100‐127 reports are adequately reviewed and agree to underlying accounting records. Effect ‐ Lack of compliance with designed internal controls over reporting could result in the Authority reporting incorrect or incomplete information. Questioned Costs ‐ None reported. Context/Sampling ‐ A nonstatistical sample of 10 reports out of 31 reports. Repeat Finding from Prior Year – Yes, prior year finding 2022‐002 Recommendation ‐ Management should determine and formalize reporting responsibilities between the Airport and the State and establish review processes to ensure that amounts included in SF‐425 and FAA Form 5100‐127 reports agree with the underlying accounting records. Views of Responsible Officials ‐ Management agrees with the finding.
Department of Transportation Federal Financial Assistance Listing 20.106; Awards AIP3‐46‐0050‐54, AIP3‐46‐0050‐59, AIP3‐46‐0050‐60, and AIP3‐46‐0050‐62. COVID‐19 Airport Improvement Program Reporting Significant Deficiency in Internal Control over Compliance Criteria ‐ 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award. 2 CFR 200.327 and 2 CFR 200.328 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 ‐ The SF‐425 annual report dated September 30, 2023, for award AIP3‐46‐0050‐54 underreported the federal share of expenditures by $80,133, while the FAA Form 5100‐127 annual report dated December 31, 2022, for all awards underreported the externally restricted assets by $397,646. Cause ‐ The Authority does not have an internal control structure designed to ensure amounts reported on SF‐425 and FAA Form 5100‐127 reports are adequately reviewed and agree to underlying accounting records. Effect ‐ Lack of compliance with designed internal controls over reporting could result in the Authority reporting incorrect or incomplete information. Questioned Costs ‐ None reported. Context/Sampling ‐ A nonstatistical sample of 10 reports out of 31 reports. Repeat Finding from Prior Year – Yes, prior year finding 2022‐002 Recommendation ‐ Management should determine and formalize reporting responsibilities between the Airport and the State and establish review processes to ensure that amounts included in SF‐425 and FAA Form 5100‐127 reports agree with the underlying accounting records. Views of Responsible Officials ‐ Management agrees with the finding.
Department of Transportation Federal Financial Assistance Listing 20.106; Awards AIP3‐46‐0050‐54, AIP3‐46‐0050‐59, AIP3‐46‐0050‐60, and AIP3‐46‐0050‐62. COVID‐19 Airport Improvement Program Reporting Significant Deficiency in Internal Control over Compliance Criteria ‐ 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award. 2 CFR 200.327 and 2 CFR 200.328 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 ‐ The SF‐425 annual report dated September 30, 2023, for award AIP3‐46‐0050‐54 underreported the federal share of expenditures by $80,133, while the FAA Form 5100‐127 annual report dated December 31, 2022, for all awards underreported the externally restricted assets by $397,646. Cause ‐ The Authority does not have an internal control structure designed to ensure amounts reported on SF‐425 and FAA Form 5100‐127 reports are adequately reviewed and agree to underlying accounting records. Effect ‐ Lack of compliance with designed internal controls over reporting could result in the Authority reporting incorrect or incomplete information. Questioned Costs ‐ None reported. Context/Sampling ‐ A nonstatistical sample of 10 reports out of 31 reports. Repeat Finding from Prior Year – Yes, prior year finding 2022‐002 Recommendation ‐ Management should determine and formalize reporting responsibilities between the Airport and the State and establish review processes to ensure that amounts included in SF‐425 and FAA Form 5100‐127 reports agree with the underlying accounting records. Views of Responsible Officials ‐ Management agrees with the finding.
Section III – Federal Award Findings and Questioned Costs Finding #2023-001: Program Title: Early Head Start Childcare Partnership Assistance Listing: 93.600 Contract Grant Number:06-HP000201-03 Federal Award Years: July 1, 2022 to June 30, 2023 Federal Agency: U.S. Department of Health and Human Services Allowable Costs and Reporting Type of Finding: Questioned Cost and Other Noncompliance Criteria: The 2 CFR part 200 establishes costs principles for determining costs applicable to Federal Award and requires costs be adequately documented. In addition, 2 CFR section 200.328 establishes financial information be reported in accordance with terms and conditions of the federal award. This award is subject to the requirements set forth in 45 CFR Part 75, which defines unliquidated obligations as obligations incurred for direct and indirect expenses incurred but not yet paid or charged to the award and does not include a future commitment of funds for which an obligation or expense has not been incurred. Condition: Based on procedures performed, we identified expenditures recorded for future program expenses totaling $160,597 not yet obligated or incurred. As a result, amounts unspent were improperly reported as unliquidated obligations on the federal financial report for the budget period ended June 30, 2023. Questioned Costs: Based on review of accounting records and reconciliation of unused federal funds prepared by Family Service, we identified questioned costs totaling $160,597 for the Early Head Start program. Cause: Lack of documentation to support costs were obligated or incurred for direct or indirect program expense for Early Head Start prior to the end of the budget period. In addition, Family Service did not request an extension for additional time to use unspent funds on future program expenses. Effect: Noncompliance with Allowable Costs and Reporting compliance requirements of the Uniform Guidance and terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend Family Service improve procedures for tracking, reporting, and use of obligated and/or unspent funds to ensure compliance with the compliance requirements and terms and conditions of the federal award. Views of responsible officials: Management agrees with the recommendations to improve tracking and reporting of obligated and/or use of unspent funds to conform with the compliance requirements and terms and conditions of the federal award. Unfortunately, the advanced funds drawn for building remodeling and maintenance were unspent because of serious delays due to systemic problems with obtaining certificates of occupancy and permits in a timely manner.
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.
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.