Finding 2025-002 – U.S. Department of Education (ED), TRIO Programs (material weakness): Information on Federal Programs – TRIO Upward Bound Assistance Listing, FAL No. 84.047, June 30, 2025 Criteria – Federal regulations require that at least two-thirds (67%) of participants served by the TRIO Upward Bound Program be low-income and first-generation college students. 20 U.S.C. § 1070a-11 34 CFR § 645.3 (Definitions); 34 CFR § 645.11 (Participant eligibility and selection). In addition, recipients are required to maintain accurate eligibility documentation and report complete and reliable participant data in the annual performance report in accordance with 2 CFR § 200.303 and 2 CFR § 200.328. Condition – The TRIO Upward Bound Program did not meet the federally required two-thirds first-generation/low-income participant threshold. The annual performance report reflected that only 51% of participants were identified as first-generation and/or low-income. During testing of participant eligibility documentation, the participant roster reflected that only 58% of participants met the first-generation and/or low-income eligibility requirement. Cause – The condition appears to be the result of insufficient internal controls over participant eligibility determination and monitoring, including: a) inadequate review procedures to ensure eligibility requirements were met prior to participant enrollment; b) lack of ongoing monitoring to ensure continued compliance with the two-thirds eligibility requirement throughout the program year and c) insufficient reconciliation between eligibility documentation and performance reporting data. Effect – Failure to meet the statutory eligibility threshold places the program out of compliance with federal requirements and may result in: a) questioned eligibility of program participants, b) increased risk of enforcement actions, including corrective action plans or repayment of federal funds.; c) possible loss or reduction of future funding and d) risk of program eligibility. Repeat Finding – Yes. Although this is a repeat finding for Upward Bound, Student Support Services was resolved in the current year. Questioned Costs – Questioned costs could not be reasonably determined for this finding due to the inability to directly associate program expenditures with individual ineligible participants. Auditor’s Perspective – From the auditor’s perspective, this finding represents material noncompliance with federal eligibility and reporting requirements for the TRIO Upward Bound Program. Federal statutes and regulations require that at least two-thirds (67%) of program participants be low-income and first-generation college students. The program’s failure to meet this threshold both in reported data (51%) and in tested eligibility documentation (58%) demonstrates a systemic breakdown in compliance, rather than an isolated or clerical error. The discrepancy between eligibility documentation and the annual performance report further indicates weaknesses in internal controls over compliance, as required by 2 CFR § 200.303. Accurate eligibility determination is a core program requirement, directly tied to the program’s statutory purpose and funding authorization. Noncompliance with this requirement undermines assurance that federal funds were used to serve the intended population. Auditor’s Perspective – (continued) Because eligibility compliance affects the allowability of participant-related costs, the inability to demonstrate that the required proportion of participants met eligibility criteria creates an elevated risk of questioned or disallowed costs. While questioned costs could not be reasonably quantified, the scope and pervasiveness of the condition support classification of this finding as material. Absent corrective action, the program remains exposed to continued noncompliance, increased federal oversight, and potential enforcement actions by the U.S. Department of Education. Strengthening eligibility controls, monitoring, and reporting reconciliation is necessary to restore compliance and reduce future audit risk. Auditor’s Recommendation – We recommend that management: a) strengthen internal controls over participant eligibility determination, including documented review and approval procedures; b) implement periodic monitoring to ensure the two-thirds first-generation/low-income require-ment is met throughout the program year; c) Ensure accurate and consistent reporting between eligibility records and annual performance reports and d) provide staff training on federal eligibility requirements for the TRIO Upward Bound Program. View of Responsible Officials – The correct 2/3 requirement percentage from the 2024-2025 TRIO Upward Bound APR is 63%; the referenced 51% was from the 2023-2024 APR. The TRIO Upward Bound Program’s fiscal year for 2024-2025 was September 1, 2024, to August 31, 2025, which is different from the College’s fiscal year. A roster was requested and submitted reflecting TRIO Upward Bound participants during the College’s fiscal year, July 1, 2024 -June 30, 2025. The submitted roster did not reflect the participants for the Program’s 2024-2025 fiscal year. Failure to meet the 2/3 requirement stems from ongoing challenges in recruiting Program participants. Recruitment has been and continues to be a challenge for TRIO Programs nationwide since the pandemic. The TRIO Upward Bound Staff are very knowledgeable about Program eligibility and documentation requirements. A thorough review of eligibility is completed to ensure applicants meet at least one (and preferably both) eligibility criteria PRIOR TO acceptance. The TRIO Upward Bound Program received funding for FY2025 (September 1, 2025, - August 31, 2026) in the full amount of $550,864.00. The receipt of a Non-Competing Continuation (NCC) Grant Award Notice means the U.S. Department of Education is giving approval to allow the Paine College TRIO Upward Bound Program to continue serving students without any stipulations to the Program or College. The Program is operating under normal terms and conditions. Program Staff is working diligently to recruit more students to ensure compliance with the 2/3 eligibility requirement for the 2025-2026 program/fiscal year.
Finding No. 2025-042 Federal Awarding Agency: USDOC Impact: Significant Deficiency, Noncompliance AL Number and Title: 11.438 PCSRT Federal Award Number: NA24NMF4380259, NA24NMFX438G0056 Applicable Compliance Requirement: Reporting Condition: Two of four randomly selected FY 25 PCSRT SF-425 federal financial reports tested did not include the recipient share of expenditures. Context: The SF-425 is a required semi-annual federal financial form used for reporting on the financial status of federal grant awards. Recipients of PCSRT grants must submit semi-annual SF-425 reports for all active federal awards. During FY 25, 20 grant awards were subject to SF-425 submission for a total of 37 required reports filed. Four reports were selected for testing. The audit identified that the recipient share of expenditures (line 10j) reported for two federal awards was not completed. Cause: The errors were due to DFG staff misunderstanding instructions for completing SF-425 reports. Federal guidance on whether the State must report the recipient share of expenditures changed prior to the fiscal year. DFG report preparation and review procedures were insufficient to identify the revised reporting requirements. Criteria: Per Title 2 CFR 200.328(c), the State must submit financial reports as required by the federal award. Title 2 CFR 200.303(a) requires the State to establish, document, and maintain effective internal controls over Federal awards that provide reasonable assurance that the State is managing Federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Effect: Inaccurate federal reporting may impair federal decision-making and may result in the federal awarding agency imposing additional conditions or taking corrective action, including additional reporting requirements or withholding/terminating funds. Questioned Costs: None Recommendation: DFG’s DAS director should strengthen procedures for the preparation and review of the SF-425 report to ensure submitted reports are accurate. Furthermore, the DAS director should work with the federal oversight agency to revise the incomplete SF-425 reports, as needed. Views of Responsible Officials: ADFG respectfully disagrees with the audit finding regarding SF-425 reporting and recipient share. During the audit period, the federal awarding agency transitioned to a new reporting system but did not issue updated written instructions, revised award terms, or formal guidance clarifying new SF-425 fields or reporting expectations. Under 2 CFR §200.328, recipients are required to submit financial reports as specified in the Federal award, and agencies may require only OMB-approved, government-wide data elements. No updated award terms or instructions were provided to ADFG during this transition. System behavior clearly indicated that certain fields were not applicable. In Grants Online, the fields were grayed out, signaling they were not required. In contrast, eRA Commons left these fields open without any explanation or guidance. NOAA now requires these fields, but this requirement was not communicated at the time of the transition. This inconsistency demonstrates that the agency had not finalized or communicated enforceable requirements for these fields during the reporting period. DFG acted reasonably and consistently based on the information available. It would be inappropriate to penalize DFG for continuing to report under prior requirements or omitting data in fields that were not previously required. The Uniform Guidance places responsibility on awarding agencies to provide clear written guidance, transition timelines, and clarification on new reporting requirements before they become enforceable. For these reasons, DFG requests that this finding be reconsidered. Our reporting complied with the award terms and the system instructions available at the time, and any changes introduced by the agency were not formally communicated or incorporated into our award during the relevant reporting period. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. DFG management reports that the federal agency did not provide updated written instructions or reporting requirements when the federal awarding agency transitioned to a new reporting system. However, DFG management is responsible for complying with federal reporting requirements. We reaffirm the finding.
Finding No. 2025-059 Federal Awarding Agency: U.S. Environmental Protection Agency (EPA) Impact: Significant Deficiency, Noncompliance AL Number and Title: 66.202 Congressionally Mandated Projects (CMP) Federal Award Number: 01J83401, 02J14601 Applicable Compliance Requirement: Reporting Condition: Unliquidated obligations as reported in two of three tested SF-425 Federal Financial Reports were inaccurate. Context: Recipients of EPA grants must submit annual SF-425 Federal Financial Reports for all active federal awards. During FY 25, five grant awards were subject to SF-425 submission of which three were tested. The audit identified that the federal share of unliquidated obligations (line 10f) reported for two federal awards were overstated by $543,052 and $523,069, respectively. DEC staff inadvertently included the State’s share of unliquidated obligations in the report. Cause: The errors were due to insufficient procedures over the preparation and review of SF-425 reports. Criteria: Title 2 CFR 200.328(c) requires the State to submit financial reports as required by the federal award. Title 2 CFR 200.303(a) requires the State to establish, document, and maintain effective internal controls over Federal awards that provide reasonable assurance that the State is managing Federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Effect: Inaccurate federal reporting may impair federal decision-making and may result in the federal awarding agency imposing additional conditions or taking corrective action, including additional requirements or withholding/terminating funds. Questioned Costs: None Recommendation: DEC’s DAS director should strengthen procedures for the preparation and review of the SF-425 report to ensure reports submitted to EPA are accurate. Furthermore, the DAS director should work with the federal oversight agency to revise the inaccurate SF-425 reports, as needed. Views of Responsible Officials: Management agrees with this finding.
2025-001 Head Start Program – Control Weakness Over Timely Reporting (Repeated 2024-003) CFDA Title: Head Start CFDA Number: 93.600 Federal Agency: Department of Health and Human Services Condition: The District does not have adequate internal controls in place to ensure that required semi-annual and annual Head Start reports are prepared and submitted timely. Context: We analyzed the submission dates of required semi-annual and annual reports by comparing the reporting period end dates to the actual submission dates. All reports tested were submitted significantly past the required deadlines of 30 days for semi-annual reports and 90 days for annual reports. Criteria: Head Start program requirements and grant agreements require that semi-annual and annual financial and performance reports be submitted within established deadlines (generally 30 days for semi-annual reports and 90 days for annual reports) to ensure timely monitoring and reimbursement by the awarding agency. Additionally, 2 CFR §200.328 requires recipients to submit performance reports at the frequency required by the federal awarding agency. Effect: Untimely submission of required reports increases the risk of noncompliance with federal program requirements and may result in delayed reimbursements, reduced oversight by the awarding agency, and potential funding consequences. Continued delays also indicate a breakdown in internal controls over grant compliance and reporting. Cause: The District does not have formalized procedures or a monitoring system in place to ensure required Head Start reports are prepared, reviewed, and submitted within required timeframes. Recommendation: We recommend the District implement policies and procedures to ensure timely preparation and submission of all required Head Start reports, including: • Establishing a reporting calendar with clearly defined deadlines, • Assigning responsibility for report preparation and review, • Implementing a tracking mechanism to monitor report status and submission dates, and • Performing supervisory review to ensure compliance with required timelines prior to submission.
Finding 2025-004 – Reporting Federal Program: Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance and Noncompliance Criteria Per 2 CFR §200.328, non-Federal entities must submit financial and performance reports that are accurate, current, and complete. Additionally, per 2 CFR §200.303, entities must maintain effective internal control over Federal awards. Treasury SLFRF guidance requires Project and Expenditure (P&E) Reports to provide complete and accurate project information. Condition The Town’s March 2025 Project and Expenditure Report contained a project description that revenue replacement funds were used on payroll costs, when the costs were construction related. This error was not identified prior to submission. Cause The condition resulted from insufficient review of financial and narrative reporting elements. Effect The report submitted to Treasury was not accurate, resulting in noncompliance with federal reporting requirements. Questioned Costs None. Repeat Finding No. Recommendation We recommend the Town strengthen controls over SLFRF reporting by establishing documented review and approval controls, ensuring alignment between project descriptions and actual use of funds, and providing training on reporting requirements. Views of Responsible Officials Management agrees with the finding and will strengthen review procedures to ensure financial and narrative reports are accurate, complete, and consistent with underlying records.
Finding Reference: 2025-006 Federal Agency: U.S. Department of Health and Human Services Federal Program Title and ALN: Child Care and Development Block Grant (CCDF Cluster) (ALN 93.575) Compliance Requirement: Reporting – Financial Reporting (L) (MW) Type of finding: Significant Deficiency in Internal Control (SD), Instance of Noncompliance (NC) Statement of Condition: During our audit procedures, we noted that during fiscal year 2024-2025, the Program did not submit the required accumulated expenditure reports within the 15-day reporting deadlines established. In addition, the final financial reports required under the award were not submitted within the 90-day deadline. Criteria Title 2 Code of Federal Regulations (CFR) Sections 200.328 and 200.329 require subrecipients to submit accurate, complete, and timely financial and performance reports in accordance with the terms and conditions of the Federal award. In addition, the subaward agreement and reporting guidelines issued by ACUDEN establish specific deadlines for the submission of required financial reports, including final reports. Cause of Condition: The condition resulted, in part, from resource constraints experienced by the Program during the fiscal year, which affected the timely preparation and submission of required financial reports to ACUDEN. Effect of Condition: The untimely submission of accumulated expenditure reports and final financial reports may impair the pass-through entity's ability to effectively monitor program activities and financial performance on a timely basis and resulted in noncompliance with the reporting requirements established under the award. Recommendation: We recommend that Program management strengthen its procedures for monitoring reporting requirements and deadlines to ensure that all required financial reports, including final reports, are submitted timely in accordance with the terms and conditions of the award. Questioned Costs: None Prior-Year Finding: This is a new finding. View of Responsible Official and Planned Corrective Action Plan: Management established corrective measures immediately upon identifying the deficiency related to the untimely submission of the required reports. The Municipality implemented formal procedures to monitor reporting deadlines and ensure the timely submission of reports required by ACUDEN. Management will continue monitoring compliance with these corrective measures to ensure the timely submission of reports in future periods. Implementation Date: July 1, 2026 Responsible Person Mrs. Mayra Ortiz Arroyo, Finance and Budget Director
CFDA Number: 93.224 Federal Program or Cluster: Health Center Program Cluster Grantor Agency: U.S. Department of Health and Human Services Federal Award Identification: H8FCS41177 Compliance Requirements: Reporting Type of Finding: Noncompliance/Material Weakness in Internal Control over Compliance Quiestioned Costs: None Criteria: 2 CFR Part 200, Section 200.302 Financial management requires that the Organization's financial management system must provide for the following: 1) Identification of all Federal awards received and expended and the Federal programs under which they were received..; and 2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in Sections 200.328 and 200.329. Section 200.328 Financial reporting states that the required financial reporting consists of the Federal Financial Report (SF-425). Condition: The SF-425 Federal Financial Report filed by the Organization for the H8FCS41177 Federal award reported that cash disbursements of $2,675,250, the total amount of the Federal award, had been made. However, $1,248,456 of those cash disbursements were determined during our audit to not be allowable due to not being obligated and/or liquidated by the period of performance deadlines. The cash disbursements reported on the SF-425 were not readily determinable from the Organization's general ledger accounts. Cause: Organization personnel were not aware of the period of performance with respect to this federal award. The Organization's previous CEO retired approximately May 31, 2024. Per inquiry of the Organizaton's CFO, their understanding was that the deadline to obligate for this federal award was December 31, 2024, and the deadline to expend or liquidate was December 31, 2026. The Organizaton's chart of accounts and general ledger do not include separate and distinct accounts or classes to which federal award expenditures are recorded. Effect or Potential Effect: The SF-425 Federal Financial Report filed by the Organization included cash disbursements of $1,248,456 that were not chargeable to the Federal award because they were not obligated before the period of performance end date and/or the payment was not made before the deadline to liquidate obligations. Context: We requested detail of expenditures for the Federal award and were provided with manual spreadsheets lacking all the transactional details needed. Information from the general ledger did not agree with cash disbursements reported on the SF-425. The general ledger information indicated $1,185,164 of the Federal award had not yet been disbursed at the time the SF-425 was filed. Repeat Finding: No Recommendation: We recommend that the Organization provide grants management training to all its financial staff and management covering the Uniform Guidance/OMB Guidance for Federal Financial Assistance. We also recommend that the Organization develop and implement policies and procedures for financial and performance report preparation to ensure information is supported by proper documentation and agrees with the general ledger. These policies and procedures should also include a requirement that all reports are reviewed by a member of management who is not involved in the preparation of the reports. Views of Responsible Officials: We agree with the finding. We have never received proper training. See Corrective Action Plan for Reference 2025-007.
Criteria: 2 CFR §200.327 and §200.328 requires recipients of federal awards to submit accurate and timely financial reports as required by the terms and conditions of the award. The Federal Financial Report (FFR) must be submitted by the due date specified in the grant agreement and must reflect accurate financial data. Condition and Context: During our audit of the Community Health Centers Cluster, we noted the entity failed to submit the required FFRs by the established deadlines for two annual reports. Additionally, two submitted reports contained inaccuracies, including expenditures that did not agree to amounts reported on the 2024 Schedule of Expenditures of Federal Awards and/or underlying supporting financial records. In one instance the report was filed 107 days late. In the second instance the report was filed 33 days late. Since this is a repeat finding, this is considered to not be an isolated instance and appears to be more indicative of a systemic problem. Effect: Failure to submit timely and accurate financial reports may result in noncompliance with federal regulations, potential withholding of future funding, and increased risk of questioned costs or audit findings. Cause: The delays and inaccuracies were attributed to inadequate internal controls over the financial reporting process, including lack of review procedures and insufficient training of staff responsible for preparing the reports. Recommendation: We recommend the entity strengthen its internal controls over the financial reporting process by implementing formal review procedures, providing staff training on federal reporting requirements, and establishing a calendar system to ensure timely submissions.
U.S. Department of Health and Human Services Federal Financial Assistance Listing 93.423 1332 State Innovation Waivers Reporting Significant Deficiency in Internal Control in Federal Compliance Criteria: Recipients of federal funds must submit financial reports as required by the Federal award. Reports submitted annually by the recipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period, in accordance with CFR § 200.328(c). Condition: The Association’s existing controls over their reporting processes, to ensure reports were submitted timely, were not functioning in such a way that ensured reports were submitted on time. Cause: The Association didn’t set a reminder or have a pre-arranged schedule that notified management a report was due. Effect: 1 quarterly report was submitted 3 days late. 1 quarterly report was submitted 2 days late. Questioned Costs: None reported Context/Sampling: Sampling was not used. 100% of the reports submitted during the year were tested. Repeat Finding from Prior Year(s): No Recommendation: Management should have a control in place to ensure they are notified that a report is coming due so they are able to compile and submit it on time. If information required to be included in the report is not available at the time the report is due, management should have a control in place to request an extension for the delayed submission of the report. Views of Responsible Officials: Management of the Association agrees with the finding.
Department of Transportation Federal Financial Assistance Listing 20.106; Awards AIP3-46-0050-59, AIP3-46-0050-62, AIP3-46-0050-63, and AIP3-46-0050-64. COVID-19 Airport Improvement Program Reporting Material Weakness in Internal Control over Compliance; Material Noncompliance 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, 2024, for award AIP3-46-0050-64 underreported the federal share of expenditures by $23,588, while the FAA Form 5100-127 annual report dated December 31, 2023, for all awards underreported the total capital expenditures and construction in progress by $2,729,962. 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 7 reports out of 27 reports. Repeat Finding from Prior Year – Yes, prior year finding 2023-002 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 AIP3-46-0050-59, AIP3-46-0050-62, AIP3-46-0050-63, and AIP3-46-0050-64. COVID-19 Airport Improvement Program Reporting Material Weakness in Internal Control over Compliance; Material Noncompliance 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, 2024, for award AIP3-46-0050-64 underreported the federal share of expenditures by $23,588, while the FAA Form 5100-127 annual report dated December 31, 2023, for all awards underreported the total capital expenditures and construction in progress by $2,729,962. 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 7 reports out of 27 reports. Repeat Finding from Prior Year – Yes, prior year finding 2023-002 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 AIP3-46-0050-59, AIP3-46-0050-62, AIP3-46-0050-63, and AIP3-46-0050-64. COVID-19 Airport Improvement Program Reporting Material Weakness in Internal Control over Compliance; Material Noncompliance 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, 2024, for award AIP3-46-0050-64 underreported the federal share of expenditures by $23,588, while the FAA Form 5100-127 annual report dated December 31, 2023, for all awards underreported the total capital expenditures and construction in progress by $2,729,962. 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 7 reports out of 27 reports. Repeat Finding from Prior Year – Yes, prior year finding 2023-002 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 AIP3-46-0050-59, AIP3-46-0050-62, AIP3-46-0050-63, and AIP3-46-0050-64. COVID-19 Airport Improvement Program Reporting Material Weakness in Internal Control over Compliance; Material Noncompliance 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, 2024, for award AIP3-46-0050-64 underreported the federal share of expenditures by $23,588, while the FAA Form 5100-127 annual report dated December 31, 2023, for all awards underreported the total capital expenditures and construction in progress by $2,729,962. 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 7 reports out of 27 reports. Repeat Finding from Prior Year – Yes, prior year finding 2023-002 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.
Finding Number: 2024-001 Federal Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year: 2024 Assistance Listing Number (ALN): 21.027 Federal Awarding Agency: U.S. Department of Treasury Compliance Requirement: Reporting – Quarterly Program Reports Pass-through Entity: Ohio Department of Development Repeat Finding: No Significant Deficiency and Noncompliance – Timely Submission of Quarterly Program Reports Criteria: 2 C.F.R. § 200.328 Financial Reporting states, in part, the Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports. The recipient must submit quarterly program reports as required by the Federal award. In the Ohio Department of Development Water and Wastewater Infrastructure Program Grant Agreement, Statement of Agreement, Section 6 Reporting Requirements, Exhibit II Reporting, Section 2, Program Reports, all grant award recipients are required to submit program reports on a quarterly basis. Quarterly program reports must be submitted by close of business, on the second Friday, at the end of each quarter. Condition: The City did not submit the quarter ending December 31, 2024 Quarterly Program Report until March 7, 2025, after the deadline of January 10, 2025. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Auditor reviewed the Quarterly Program Report for period ending December 31, 2024 via email submission to Ohio Department of Development, and noted the City did not submit the report until March 7, 2025, which was after the deadline of January 10, 2025. These requirements are outlined in the federal award agreement and applicable UG provisions. Cause and Effect: The issue results of lack of monitoring control related to grant reporting requirements. Failure to submit reports as required, could result in non-compliance with grant requirements. Recommendation: We recommend that the City implement procedures and internal deadlines for reviewing and timely submitting all reports under federal awards. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2024-001 Federal Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year: 2024 Assistance Listing Number (ALN): 21.027 Federal Awarding Agency: U.S. Department of Treasury Compliance Requirement: Reporting – Quarterly Program Reports Pass-through Entity: Ohio Department of Development Repeat Finding: No Significant Deficiency and Noncompliance – Timely Submission of Quarterly Program Reports Criteria: 2 C.F.R. § 200.328 Financial Reporting states, in part, the Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports. The recipient must submit quarterly program reports as required by the Federal award. In the Ohio Department of Development Water and Wastewater Infrastructure Program Grant Agreement, Statement of Agreement, Section 6 Reporting Requirements, Exhibit II Reporting, Section 2, Program Reports, all grant award recipients are required to submit program reports on a quarterly basis. Quarterly program reports must be submitted by close of business, on the second Friday, at the end of each quarter. Condition: The City did not submit the quarter ending December 31, 2024 Quarterly Program Report until March 7, 2025, after the deadline of January 10, 2025. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Auditor reviewed the Quarterly Program Report for period ending December 31, 2024 via email submission to Ohio Department of Development, and noted the City did not submit the report until March 7, 2025, which was after the deadline of January 10, 2025. These requirements are outlined in the federal award agreement and applicable UG provisions. Cause and Effect: The issue results of lack of monitoring control related to grant reporting requirements. Failure to submit reports as required, could result in non-compliance with grant requirements. Recommendation: We recommend that the City implement procedures and internal deadlines for reviewing and timely submitting all reports under federal awards. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding: Reporting Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and COVID-19 Airports Programs Assistance Listing Number: 20.106 Department of Transportation, Award Number 3-05-0047-031-2023, Award Year 2023 Department of Transportation, Award Number 3-05-0047-032-2024, Award Year 2024 Criteria: In accordance with 2 CFR section 200.328, recipients must use the standard financial reporting forms when reporting to the federal awarding agency. Each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the federal awarding agency. Recipients use the Federal Financial Report (FFR) (SF-425/SF-425A) as a standardized format to report expenditures under federal awards, as well as, when applicable, cash status (lines 10.a, 10.b, and 10c). Condition: We noted the City did not complete and submit the required annual Federal Financial Reports (SF-425) for the two awards identified above during the year ended December 31, 2024. Questioned Costs: None Context: We identified and tested both FFR (SF-425) reports that were required to be completed and submitted for the year ended December 31, 2024, and noted the reports were not submitted as described above. Effect: Failure to complete and submit reports could lead to inaccurate reporting of information to the Federal Aviation Administration. In addition, failure to submit required reports to the Federal Aviation Administration could result in non-compliance and revocation of awarded grant funds. Cause: Controls over reporting were not sufficiently operating during the year primarily due to staffing issues and turnover within the Airport Department. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the City develop a process for reviewing and tracking the submission of FFR reporting to the Federal Aviation Administration. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.
Finding Number: 2024-001 Federal Program: COVID-19: SLFRF-Water and Wastewater Infrastructure Program Federal Award Identification Number and Year: DEV-2021-181504, DEV-2021-181549 Assistance Listing Number (ALN): 21.027 Federal Awarding Agency: Department of Treasury Pass-through Entity: Ohio Department of Development Repeat Finding: No Significant Deficiency and Noncompliance – Reporting Criteria: 2 C.F.R. § 200.328 Financial Reporting states, in part, the Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports. The recipient must submit quarterly program reports as required by the Federal award. In the Ohio Department of Development Water and Wastewater Infrastructure Program Grant Agreement, Statement of Agreement, Section 6 Reporting Requirements, Exhibit II Reporting, Section 2, Program Reports, all grant award recipients are required to submit program reports on a quarterly basis. Quarterly program reports must be submitted by close of business, on the second Friday, at the end of each quarter. In addition, the Ohio Department of Development Water and Wastewater Infrastructure Program Grant Agreement, Statement of Agreement Section 6 Reporting Requirements, Exhibit II Reporting, Section 1 states all financial reimbursement requests must be submitted electronically to the Grantor on a monthly basis as costs are incurred. Condition: The Conservancy District did not submit the required Program Report for the first quarter of 2024. In addition, federal financial reimbursement request for December 2023 activity was not submitted until February 2024. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Through testing of required reporting under terms and conditions of the federal award, we observed the Conservancy District did not meet required timeliness for financial and performance reporting. Specifically, one reimbursement request for costs incurred in December 2023 was delayed until February 2024. The required performance reporting for the first quarter of 2024 was not submitted. These requirements are outlined in the federal award agreement and applicable UG provisions. Cause and Effect: The issue results from a lack of monitoring control related to grant reporting requirements. Failure to submit reports as required, could result in noncompliance with grant requirements. Recommendation: We recommend management implement procedures and internal deadlines for reviewing and timely submitting all reports under federal awards. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2024-001 Federal Program: COVID-19: SLFRF-Water and Wastewater Infrastructure Program Federal Award Identification Number and Year: DEV-2021-181504, DEV-2021-181549 Assistance Listing Number (ALN): 21.027 Federal Awarding Agency: Department of Treasury Pass-through Entity: Ohio Department of Development Repeat Finding: No Significant Deficiency and Noncompliance – Reporting Criteria: 2 C.F.R. § 200.328 Financial Reporting states, in part, the Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports. The recipient must submit quarterly program reports as required by the Federal award. In the Ohio Department of Development Water and Wastewater Infrastructure Program Grant Agreement, Statement of Agreement, Section 6 Reporting Requirements, Exhibit II Reporting, Section 2, Program Reports, all grant award recipients are required to submit program reports on a quarterly basis. Quarterly program reports must be submitted by close of business, on the second Friday, at the end of each quarter. In addition, the Ohio Department of Development Water and Wastewater Infrastructure Program Grant Agreement, Statement of Agreement Section 6 Reporting Requirements, Exhibit II Reporting, Section 1 states all financial reimbursement requests must be submitted electronically to the Grantor on a monthly basis as costs are incurred. Condition: The Conservancy District did not submit the required Program Report for the first quarter of 2024. In addition, federal financial reimbursement request for December 2023 activity was not submitted until February 2024. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Through testing of required reporting under terms and conditions of the federal award, we observed the Conservancy District did not meet required timeliness for financial and performance reporting. Specifically, one reimbursement request for costs incurred in December 2023 was delayed until February 2024. The required performance reporting for the first quarter of 2024 was not submitted. These requirements are outlined in the federal award agreement and applicable UG provisions. Cause and Effect: The issue results from a lack of monitoring control related to grant reporting requirements. Failure to submit reports as required, could result in noncompliance with grant requirements. Recommendation: We recommend management implement procedures and internal deadlines for reviewing and timely submitting all reports under federal awards. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2024-001 Federal Program: CDBG – Entitlement Grants Cluster Federal Award Identification Number and Year: B20MC390014 (2020), B21MC390014 (2021), B22MC390014 (2022), B23MC390014 (2023), B24MC390014 (2024), B20MW390014 (2020) Assistance Listing Number (ALN): 14.218 Federal Awarding Agency: Department of Housing and Urban Development Pass-through Entity: None Repeat Finding: No Significant Deficiency 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 submitted its second quarter 2024 financial reports due July 30, 2024 on November 6, 2024 and its fourth quarter financial reports due January 30, 2025 on April 8, 2025. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Through testing required reporting under terms and conditions of the federal award, we observed the City failed to meet the expected timelines for financial reporting. Specifically, we identified the second and fourth quarter reports were submitted after the stated deadline. These requirements are outlined in the federal award agreement and applicable Uniform Guidance provisions. Cause and Effect: The issue results of lack of monitoring control related to grant reporting requirements. Failure to submit reports as required could result in non-compliance with grant requirements. Recommendation: We recommend that the City implement procedures and internal deadlines for reviewing and timely submitting all reports under federal awards. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2024-001 Federal Program: CDBG – Entitlement Grants Cluster Federal Award Identification Number and Year: B20MC390014 (2020), B21MC390014 (2021), B22MC390014 (2022), B23MC390014 (2023), B24MC390014 (2024), B20MW390014 (2020) Assistance Listing Number (ALN): 14.218 Federal Awarding Agency: Department of Housing and Urban Development Pass-through Entity: None Repeat Finding: No Significant Deficiency 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 submitted its second quarter 2024 financial reports due July 30, 2024 on November 6, 2024 and its fourth quarter financial reports due January 30, 2025 on April 8, 2025. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Through testing required reporting under terms and conditions of the federal award, we observed the City failed to meet the expected timelines for financial reporting. Specifically, we identified the second and fourth quarter reports were submitted after the stated deadline. These requirements are outlined in the federal award agreement and applicable Uniform Guidance provisions. Cause and Effect: The issue results of lack of monitoring control related to grant reporting requirements. Failure to submit reports as required could result in non-compliance with grant requirements. Recommendation: We recommend that the City implement procedures and internal deadlines for reviewing and timely submitting all reports under federal awards. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2024-001 Federal Program: CDBG – Entitlement Grants Cluster Federal Award Identification Number and Year: B20MC390014 (2020), B21MC390014 (2021), B22MC390014 (2022), B23MC390014 (2023), B24MC390014 (2024), B20MW390014 (2020) Assistance Listing Number (ALN): 14.218 Federal Awarding Agency: Department of Housing and Urban Development Pass-through Entity: None Repeat Finding: No Significant Deficiency 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 submitted its second quarter 2024 financial reports due July 30, 2024 on November 6, 2024 and its fourth quarter financial reports due January 30, 2025 on April 8, 2025. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Through testing required reporting under terms and conditions of the federal award, we observed the City failed to meet the expected timelines for financial reporting. Specifically, we identified the second and fourth quarter reports were submitted after the stated deadline. These requirements are outlined in the federal award agreement and applicable Uniform Guidance provisions. Cause and Effect: The issue results of lack of monitoring control related to grant reporting requirements. Failure to submit reports as required could result in non-compliance with grant requirements. Recommendation: We recommend that the City implement procedures and internal deadlines for reviewing and timely submitting all reports under federal awards. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2024-001 Federal Program: CDBG – Entitlement Grants Cluster Federal Award Identification Number and Year: B20MC390014 (2020), B21MC390014 (2021), B22MC390014 (2022), B23MC390014 (2023), B24MC390014 (2024), B20MW390014 (2020) Assistance Listing Number (ALN): 14.218 Federal Awarding Agency: Department of Housing and Urban Development Pass-through Entity: None Repeat Finding: No Significant Deficiency 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 submitted its second quarter 2024 financial reports due July 30, 2024 on November 6, 2024 and its fourth quarter financial reports due January 30, 2025 on April 8, 2025. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Through testing required reporting under terms and conditions of the federal award, we observed the City failed to meet the expected timelines for financial reporting. Specifically, we identified the second and fourth quarter reports were submitted after the stated deadline. These requirements are outlined in the federal award agreement and applicable Uniform Guidance provisions. Cause and Effect: The issue results of lack of monitoring control related to grant reporting requirements. Failure to submit reports as required could result in non-compliance with grant requirements. Recommendation: We recommend that the City implement procedures and internal deadlines for reviewing and timely submitting all reports under federal awards. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2024-001 Federal Program: CDBG – Entitlement Grants Cluster Federal Award Identification Number and Year: B20MC390014 (2020), B21MC390014 (2021), B22MC390014 (2022), B23MC390014 (2023), B24MC390014 (2024), B20MW390014 (2020) Assistance Listing Number (ALN): 14.218 Federal Awarding Agency: Department of Housing and Urban Development Pass-through Entity: None Repeat Finding: No Significant Deficiency 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 submitted its second quarter 2024 financial reports due July 30, 2024 on November 6, 2024 and its fourth quarter financial reports due January 30, 2025 on April 8, 2025. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Through testing required reporting under terms and conditions of the federal award, we observed the City failed to meet the expected timelines for financial reporting. Specifically, we identified the second and fourth quarter reports were submitted after the stated deadline. These requirements are outlined in the federal award agreement and applicable Uniform Guidance provisions. Cause and Effect: The issue results of lack of monitoring control related to grant reporting requirements. Failure to submit reports as required could result in non-compliance with grant requirements. Recommendation: We recommend that the City implement procedures and internal deadlines for reviewing and timely submitting all reports under federal awards. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2024-001 Federal Program: CDBG – Entitlement Grants Cluster Federal Award Identification Number and Year: B20MC390014 (2020), B21MC390014 (2021), B22MC390014 (2022), B23MC390014 (2023), B24MC390014 (2024), B20MW390014 (2020) Assistance Listing Number (ALN): 14.218 Federal Awarding Agency: Department of Housing and Urban Development Pass-through Entity: None Repeat Finding: No Significant Deficiency 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 submitted its second quarter 2024 financial reports due July 30, 2024 on November 6, 2024 and its fourth quarter financial reports due January 30, 2025 on April 8, 2025. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Through testing required reporting under terms and conditions of the federal award, we observed the City failed to meet the expected timelines for financial reporting. Specifically, we identified the second and fourth quarter reports were submitted after the stated deadline. These requirements are outlined in the federal award agreement and applicable Uniform Guidance provisions. Cause and Effect: The issue results of lack of monitoring control related to grant reporting requirements. Failure to submit reports as required could result in non-compliance with grant requirements. Recommendation: We recommend that the City implement procedures and internal deadlines for reviewing and timely submitting all reports under federal awards. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
VA Supportive Services for Veteran Families Program FFAL #64.033, 20-SD-136-23, 10/1/2022 – 3/1/2024 FFAL #64.033, 20-SD-136-24, 10/1/2023 – 12/31/2024 Reporting Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.328 and 2 CFR 200.329 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with the program requirements. Condition: No review and approval processes are in place over quarterly progress reports. Cause: Management did not have review procedures and processes in place over the quarterly progress reports. Effect: Without review procedures and processes in place over reporting, demonstrating the program complies with laws, regulations, and other compliance requirements is difficult. Additionally, not having an oversight process over reporting could result in a reasonable possibility reports that are inaccurate or incomplete could be submitted. Questioned Costs: None reported Context/Sampling: Included under the two award letters of the federal program, one annual financial report and one quarterly progress report was reviewed in the Organization’s fiscal year. In addition, two monthly HMIS reports were reviewed in the Organization’s fiscal year. There was a total of 18 reports filed. Repeat Finding from Prior Year: No Recommendation: We recommend management implement procedures and control processes to incorporate an independent review and approval over reporting and retain documentation to support the review was performed. Views of Responsible Officials: Management is in agreement.
VA Supportive Services for Veteran Families Program FFAL #64.033, 20-SD-136-23, 10/1/2022 – 3/1/2024 FFAL #64.033, 20-SD-136-24, 10/1/2023 – 12/31/2024 Reporting Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.328 and 2 CFR 200.329 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with the program requirements. Condition: No review and approval processes are in place over quarterly progress reports. Cause: Management did not have review procedures and processes in place over the quarterly progress reports. Effect: Without review procedures and processes in place over reporting, demonstrating the program complies with laws, regulations, and other compliance requirements is difficult. Additionally, not having an oversight process over reporting could result in a reasonable possibility reports that are inaccurate or incomplete could be submitted. Questioned Costs: None reported Context/Sampling: Included under the two award letters of the federal program, one annual financial report and one quarterly progress report was reviewed in the Organization’s fiscal year. In addition, two monthly HMIS reports were reviewed in the Organization’s fiscal year. There was a total of 18 reports filed. Repeat Finding from Prior Year: No Recommendation: We recommend management implement procedures and control processes to incorporate an independent review and approval over reporting and retain documentation to support the review was performed. Views of Responsible Officials: Management is in agreement.
FINDING 2024-004 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 Listings Number: 10.760 Federal Award Number and Year (or Other Identifying Number): FY2024 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 2023-003. Condition and Context 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, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The Town was required to submit the following reporting to the Department of Agriculture annually: • Statement of Budget, Income, and Equity (Form RD 442-2) • Balance Sheet (Form RD 442-3) INDIANA STATE BOARD OF ACCOUNTS 21 TOWN OF PAOLI SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The Form RD 442-2 covers financial operations relating to the Town's wastewater utility and the Form RD 442-3 presents the financial status of the wastewater utility. In both instances, a borrower may submit the financial data on other forms, provided the forms are in a similar format and signed and dated by the organization's official to certify the correctness of the information. Alternatively, an annual audit may be submitted in lieu of the forms. The Town did not submit the Form RD 442-2 during the audit period as required. The Town submitted the Form RD 442-3 reporting 2023 data in 2024 as required. However, this report is intended to be a comparative balance sheet as described in the USDA Rural Utilities Service Borrower's Guide. The Town did not include comparative data for 2022 in the report. There was also no documentation or other evidence of an oversight, review, or approval process for the report that was filed. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 7 CFR 1780.47 states in part: "(a) Borrowers are required to provide RUS an annual audit or financial statements. . . . (e) Borrowers exempt from audits. All borrowers who are exempt from audits, will, within 60 days following the end of each fiscal year, furnish the RUS with annual financial statements, consisting of a verification of the organization's balance sheet and statement of income and expense by an appropriate official of the organization. Forms RD 442-2, 'Statement of Budget, Income and Equity,' and 442-3 may be used. INDIANA STATE BOARD OF ACCOUNTS 22 TOWN OF PAOLI SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (f) Management reports. These reports will furnish management with a means of evaluating prior decisions and serve as a basis for planning future operations and financial strategies. In those cases where revenues from multiple sources are pledged as security for an RUS loan, two reports will be required; one for the project being financed by RUS and one combining the entire operation of the borrower. In those cases where RUS loans are secured by general obligation bonds or assessments and the borrower combines revenues from all sources, one management report combining all such revenues is acceptable. The following management data will be submitted by the borrower to the processing office. These reports at a minimum will include a balance sheet and income and expense statement. . . . (2) Annual management reports. Prior to the beginning of each fiscal year the following will be submitted to the processing office. (If Form RD 442-2 is used as the annual management report, enter data in column three only of Schedule 1, and complete all of Schedule 2.) (i) Two copies of the management reports and proposed 'Annual Budget'. (ii) Financial information may be reported on Form RD 442-2 which includes Schedule 1, 'Statement of Budget, Income and Equity' and Schedule 2, 'Projected Cash Flow' or information in similar format. (iii) A copy of the rate schedule in effect at the time of submission. . . ." Cause The Clerk-Treasurer was only in her first year of her first term in office when these were due. As such, she was unfamiliar with the reporting requirements of the grant. Effect Without a proper system of internal controls in place that operated effectively, the Town did not file one of the two required reports, and the report that was filed was incomplete. As a result, material noncompliance occurred and remained undetected. By not reporting the comparative data, all information needed to determine the true financial status of the Town was not readily available. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Town's management establish a proper system of internal controls and develop and implement reporting policies and procedures to ensure that all required reports are filed timely, accurately, and contain all the required information. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding Number: 2024-002 - Preparation of the Schedule of Expenditures of Federal Awards Criteria: The District should report federal grant expenditures on an accrual basis of accounting in order to be consistent with the District's financial statements. Per 2 CFR §200.328, recipients of federal awards must submit financial reports such as those required by the Vermont Community Broadband Board (VCBB). Timely and accurate submission of these reports is critical for demonstrating compliance, accountability, and program effectiveness. Condition Found: The District is currently reporting grant expenditures on a cash basis which is not consistent with the financial statements, which are prepared using the accrual basis of accounting. As a result, grant expenditures could be reported in improper periods. Cause and Effect: Having to adjust for accrual account balances resulted in errors that an ongoing accrual accounting process would have helped prevent or detect and correct timely. As a result of this condition, the Schedule of Expenditures of Federal Awards had to be corrected to reflect expenditures that had been accrued in the District's financial statements. Recommendation: We recommend that the District implement policies and procedures to report grant expenditures on the accrual basis of accounting throughout the year. Identification as a Repeat Finding, if applicable A repeat finding; See finding 2023-002 Questioned costs None Management response: Management agrees with the findings and recommendations.
Finding Number: 2024-002 - Preparation of the Schedule of Expenditures of Federal Awards Criteria: The District should report federal grant expenditures on an accrual basis of accounting in order to be consistent with the District's financial statements. Per 2 CFR §200.328, recipients of federal awards must submit financial reports such as those required by the Vermont Community Broadband Board (VCBB). Timely and accurate submission of these reports is critical for demonstrating compliance, accountability, and program effectiveness. Condition Found: The District is currently reporting grant expenditures on a cash basis which is not consistent with the financial statements, which are prepared using the accrual basis of accounting. As a result, grant expenditures could be reported in improper periods. Cause and Effect: Having to adjust for accrual account balances resulted in errors that an ongoing accrual accounting process would have helped prevent or detect and correct timely. As a result of this condition, the Schedule of Expenditures of Federal Awards had to be corrected to reflect expenditures that had been accrued in the District's financial statements. Recommendation: We recommend that the District implement policies and procedures to report grant expenditures on the accrual basis of accounting throughout the year. Identification as a Repeat Finding, if applicable A repeat finding; See finding 2023-002 Questioned costs None Management response: Management agrees with the findings and recommendations.
Condition: During our audit of the District’s compliance with federal program requirements, we noted that the District does not have established internal controls over the reporting process. Specifically, there are no formal procedures in place to ensure the accuracy, completeness, and timeliness of required federal reports. Criteria: In accordance with 2 CFR §200.328(b)(1) and the specific terms and conditions of the federal award agreement, recipients are required to submit performance and/or financial reports quarterly, no later than the 21st day of the following month after the end of each calendar quarter. Timely submission of these reports is essential for the federal awarding agency to monitor progress and compliance with program objectives. Cause: This is the first year the District has been subject to a single audit, exceeding the $750,000 expenditure threshold, and did not have adequate internal controls in place to ensure that reporting deadlines were tracked and met consistently. Oversight of the reporting calendar and assignment of responsibilities were not clearly documented. Effect: Failure to submit required reports on time constitutes noncompliance with federal grant requirements. Late submissions may impede the federal agency’s ability to monitor the project’s progress and may affect future funding decisions or lead to additional oversight. Recommendation: We recommend that the District strengthen its internal control system by implementing a formal tracking mechanism for federal reporting deadlines, assigning responsibility for report preparation and submission, and establishing a review process to ensure timely compliance with all grant reporting requirements. Views of Responsible Officials: See the attached Corrective Action Plan.
Condition: During our review of the District’s reporting procedures, we noted that the District does not have a documented or formalized internal review process for the preparation and submission of required quarterly reports. Reports are typically prepared and submitted by a single individual without supervisory review or approval. Criteria: In accordance with 2 CFR §200.328(b)(1), non-Federal entities are required to submit performance and/or financial reports on a regular basis as specified in the terms and conditions of the award. Effective internal controls, as outlined in 2 CFR §200.303, require that entities establish and maintain processes to ensure reliable reporting and compliance with federal requirements. Cause: This is the first year the District has been subject to a single audit, exceeding the $750,000 expenditure threshold, and has not yet developed formal policies or procedures for reviewing and approving required financial and programmatic reports. Effect: The absence of a formal review process increases the risk of reporting errors, late submissions, or omissions that could lead to noncompliance with federal reporting requirements. It also reduces the ability to detect and correct potential reporting deficiencies before submission to the federal awarding agency. Recommendation: We recommend that the District develop and implement formal policies and procedures to ensure that federal reports are reviewed for accuracy, completeness, and timeliness prior to submission. Management should assign responsibility for report preparation and review, implement checklists or reconciliation processes, and provide training to staff involved in federal reporting. Views of Responsible Officials: See the attached Corrective Action Plan.
Section III - Findings or questioned costs for Federal awards, including those specified by the Uniform Guidance. 2024-003 Compliance with Reporting Requirements for COVID-19 State and Local Fiscal Recovery Funds Federal Program, Assistance Listing Number, Federal Award Year, Federal Agency COVID-19 State and Local Fiscal Recovery Funds – American Rescue Plan Act, 21.027, 2024, U.S. Department of Treasury Criteria or Specific Requirement Uniform Guidance 2 CFR 200.328 and 31 CFR section 45.4(c) require accurate reporting for key line items within Federal performance reports. Condition Found Reports submitted to the Department of the Treasury for COVID-19 State and Local Fiscal Recovery Funds did not include all expenditures applicable to the reporting period. Cause: After spending approximately 30 years with the Police Jury, the Treasurer retired in November 2024, and a new Treasurer was not hired until the end of May 2025. Additionally, two other accounting staff members (approximately 29% of accounting personnel) resigned/retired during the late 2024/early 2025 timeframe. A consulting CPA assisted with operations in the interim between Treasurers. The Treasurer is responsible for ensuring that internal controls are properly designed and operating effectively, and for managing most of the financial close processes. The limited staff exercised diligence to accomplish much of the financial close process, but timeliness was an issue as the staff was operating with an increased workload, and not all responsibilities handled by the Treasurer were fully addressed. Effect: Cumulative expenditures reported to the Department of the Treasury were understated by $382,277 of $10,254,543 total expenditures. Questioned Costs N/A Recommendations to Prevent Future Occurrences The Police Jury should ensure the new Treasurer is proactive in the next financial close process and reviews their policies and procedures and the Louisiana Legislative Auditor’s best practices to ensure that internal controls are properly designed, implemented, and maintained to ensure accurate and timely financial close and reporting. Management’s Response Refer to corrective action plan.
2024-001 Internal Control over Compliance and Compliance with Reporting Criteria: CFR Section §200.328(c) states in part: “The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period.” Condition: The internal controls implemented to ensure the timely submission of the quarterly financial report and quarterly performance report within 30 days after the end of the reporting period did not function as intended. During our testing of reporting compliance, BDO noted that the following reports were not submitted on time due to staff unavailability for preparation and submission: • One financial report (quarter 1) for ALN 19.801 • One financial report (quarter 2) and one programmatic report (quarter 1) for ALN 98.001 Cause: The Organization's internal controls, designed to ensure compliance with reporting regulations, failed to function as intended. As a result, they did not effectively address the requirement to submit financial reports in a timely manner and meet the established deadlines. Effect: The failure of the Organization's internal controls to operate as designed has led to delays in the submission of the required financial reports, potentially resulting in non-compliance with the requirements of CFR Section §200.328(c). Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend that management evaluate the current controls to confirm they are strong and capable of effectively meeting the requirements for timely financial report submission. Additionally, management should ensure there are sufficient staff members available to prepare and submit the reports. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2024-001 Internal Control over Compliance and Compliance with Reporting Criteria: CFR Section §200.328(c) states in part: “The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period.” Condition: The internal controls implemented to ensure the timely submission of the quarterly financial report and quarterly performance report within 30 days after the end of the reporting period did not function as intended. During our testing of reporting compliance, BDO noted that the following reports were not submitted on time due to staff unavailability for preparation and submission: • One financial report (quarter 1) for ALN 19.801 • One financial report (quarter 2) and one programmatic report (quarter 1) for ALN 98.001 Cause: The Organization's internal controls, designed to ensure compliance with reporting regulations, failed to function as intended. As a result, they did not effectively address the requirement to submit financial reports in a timely manner and meet the established deadlines. Effect: The failure of the Organization's internal controls to operate as designed has led to delays in the submission of the required financial reports, potentially resulting in non-compliance with the requirements of CFR Section §200.328(c). Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend that management evaluate the current controls to confirm they are strong and capable of effectively meeting the requirements for timely financial report submission. Additionally, management should ensure there are sufficient staff members available to prepare and submit the reports. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2024-001 Internal Control over Compliance and Compliance with Reporting Criteria: CFR Section §200.328(c) states in part: “The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period.” Condition: The internal controls implemented to ensure the timely submission of the quarterly financial report and quarterly performance report within 30 days after the end of the reporting period did not function as intended. During our testing of reporting compliance, BDO noted that the following reports were not submitted on time due to staff unavailability for preparation and submission: • One financial report (quarter 1) for ALN 19.801 • One financial report (quarter 2) and one programmatic report (quarter 1) for ALN 98.001 Cause: The Organization's internal controls, designed to ensure compliance with reporting regulations, failed to function as intended. As a result, they did not effectively address the requirement to submit financial reports in a timely manner and meet the established deadlines. Effect: The failure of the Organization's internal controls to operate as designed has led to delays in the submission of the required financial reports, potentially resulting in non-compliance with the requirements of CFR Section §200.328(c). Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend that management evaluate the current controls to confirm they are strong and capable of effectively meeting the requirements for timely financial report submission. Additionally, management should ensure there are sufficient staff members available to prepare and submit the reports. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2024-001 – Congressionally Mandated Projects Assistance Listing #66.202 – Reporting Condition During our review of reporting requirements under the Congressionally Mandated Projects program, we noted that the quarterly performance report for the quarter ended December 31, 2024, was submitted to the Environmental Protection Agency (“EPA”) in June 2025 – 5 months past the required submission deadline of January 30, 2025. Criteria Per the grant agreement and the EPA’s grant-specific programmatic terms and conditions for EPA community grants, recipients are required to submit quarterly performance reports no later than 30 days following the end of each federal fiscal quarter. This requirement is also consistent with 2 CFR § 200.328(b)(1), which mandates that recipients submit performance reports in accordance with the frequency required by the federal awarding agency. Cause The delay occurred due to an oversight within the department administering the grant. Effect Failure to submit required reports on time may result in noncompliance with grant terms and could adversely impact the entity’s ability to receive continued or future federal funding. Additionally, untimely reporting limits the EPA’s ability to monitor project performance and ensure accountability for federal funds. Questioned Costs None Recommendation We recommend that management establish a formal grants calendar with automated reminders for all reporting deadlines and designate individuals responsible for preparing and submitting reports. Additionally, periodic training should be provided to ensure that all responsible personnel are aware of federal reporting requirements. View of Responsible Official The Town will establish procedures to ensure timely reporting.
2024-002 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing #21.027 – Reporting Condition The auditee submitted one or more required quarterly Project and Expenditure Reports to the U.S. Department of the Treasury after the established submission deadlines. For example, the report for the quarter ending December 31, 2024, was submitted on February 11, 2025, which was 11 days past the deadline of January 31, 2025. Criteria According to the U.S. Department of the Treasury’s Compliance and Reporting Guidance for State and Local Fiscal Recovery Funds (most recently updated April 29, 2025), recipients are required to submit quarterly Project and Expenditure Reports no later than 30 days after the end of each calendar quarter. Timely submission is required to maintain compliance with federal grant reporting requirements under 2 CFR §200.328(b)(1), which states that recipients must submit performance reports by the required due dates. Cause The delay in submitting the reports was primarily due to confusion on how to report obligated amounts in the Project and Expenditure Report. Specifically uncertain about how to report obligations in accordance with Treasury guidance, which delayed the completion and submission of the report. Effect Late submission of required federal reports may result in noncompliance with grant terms and conditions, increased scrutiny from the granting agency, and potential impacts on future funding. Furthermore, untimely reporting can hinder transparency and federal oversight of how SLFRF funds are being used. Questioned Costs None Recommendation We recommend that management implement stronger internal controls to ensure timely preparation and submission of all required federal reports. This may include designating a responsible official for compliance tracking, developing a calendar of reporting deadlines with automated reminders, and performing periodic reviews to ensure submission timelines are met. Management should also ensure that staff responsible for federal reporting are adequately trained on applicable requirements and deadlines. View of Responsible Official The Town will establish policies and procedures to comply with SLFRF reporting and guidelines to ensure timely and accurate reporting.
Identification of the Federal Program: Federal Agency and Program Name: U.S. Department of Health and Human Services Hospital Preparedness Program (HPP) Ebola Preparedness and Response Activities Award Year(s): 2024 Assistance Listing #: 93.817 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR 200.303 requires that 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR section 200.328(c) requires that recipients of Federal funding “must submit financial reports as required by the Federal award.” Condition: For one of the two Federal Financial Reports (FFRs) submitted in FY 2024, incorrect project/grant period dates and federal share of expenditures amount was reported in the FFR. Cause: Corewell did not have sufficient internal controls to follow the FFR instructions and report the correct amounts. Effect or Potential Effect: The information reported and provided to the Federal awarding agency could be incomplete or inaccurate. Questioned Costs: None Context: Corewell submitted 2 FFR reports in FY 2024. The FFR instructions required reporting the cumulative Federal share of expenditures amount ($2,253,211) from the date of inception of the award (9/30/2022) through the end date of the reporting period specified. However, Corewell reported only the current period expenditures ($933,054) for the current grant year and consequently, this error also resulted in incorrect amount reported for Unliquidated balance of Federal funds. The total federal expenditures for HPP for FY 2024 were $1,292,999. Identification as a Repeat Finding: This is not a repeat finding.Recommendation: We recommend management strengthen its internal controls and procedures over review of the data in the FFR prior to submission of the report(s). Views of Responsible Officials: Management will develop a written protocol and tracking matrix to record and track all federally funded projects that report through the Payment Management System (PMS) to ensure the correct period of performance report is created and a second level of review performed on a timely basis in accordance with sponsor requirements prior to submission.
Federal Agency: U.S. Department of Health and Human Services Assistance Listing Numbers: 93.623 Federal Program Titles: Transitional Living for Homeless Youth; Basic Center Grant 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 Federal Financial Reports within the timeframe outlined in the grant agreement. Questioned Costs: None. Context: During our testing of financial reports, The Adams Group, LLC noted the 2nd quarter and 4th quarter Federal Financial Reports for ALN 93.623 were submitted outside of the prescribed timeframe. 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 2024-002 – Reporting – Significant Deficiency in Internal Controls Over Compliance and Noncompliance Federal program information: Funding agency: Department of Energy Title: Performance Partnership Grants ALN Number: 66.605 Award year and number: 2022-2026 Criteria: In accordance with 2 CFR 200.327 and 2 CFR 200.328 (Uniform Guidance), recipients of federal funds must file complete, accurate, and timely financial reports using the prescribed standard reporting forms (e.g., SF-425). These reports must be supported by the recipient’s underlying accounting records and signed by authorized personnel. Condition/Context: The Tribe was unable to provide documentation demonstrating that the required Federal Financial Report (FFR) for the year ended September 30, 2024, was submitted. As a result, we could not determine whether the FFR was filed in a timely manner or whether it included the proper authorization signature. Cause/Effect: The apparent lack of formal procedures or controls for retaining evidence of FFR submissions contributed to the unavailability of supporting documentation. The absence of evidence of submission and authorization could result in noncompliance with federal reporting requirements. If the report was not submitted timely or was not signed by authorized personnel, the Tribe may be subject to adverse consequences, including potential questioning of costs, additional oversight, or delays in future funding. Repeat Finding – This is not a repeat finding. Auditor’s Recommendations: The Tribe should implement and maintain a standardized process, which includes clearly documented procedures, for retaining evidence of financial report submissions. This process should ensure that each FFR is filed promptly, reviewed by appropriate officials, and accompanied by documentation showing the submission date, authorized signature, and confirmation of receipt from the federal agency, if available. Management’s Response: The Tribe has drafted a comprehensive Financial Management Policies and Procedures Manual, which includes a section specific to grants management and procurement, that will provide guidance for month end close, asset management and preparation of the Schedule of Expenditures of Federal Awards, Reporting, etc. The Financial Management Policies and Procedures Manual will be presented to the Tribal Council for review and adoption by December 2025. Additionally, the Tribe has a third-party CPA firm to conduct mandatory Uniform Guidance training and regular grant compliance and accounting training for all program and accounting staff working with grant awards.
FINDING 2024-002 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): ARP Act Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon type of recipient and its population, as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. The City was classified as a city with a population below 250,000 residents that received an allocation of more than $10 million in COVID-19 - Coronavirus State and Local Fiscal Recovery Funds. The quarterly reports were to cover one calendar quarter and must be submitted to the Treasury by the last day of the month following the end of the period covered. The City submitted all required P&E reports during the audit period. The internal controls in place were not effective and did not prevent, or detect and correct, errors in the P&E reports prior to submission. All four quarterly reports submitted contained errors; obligations and expenditures were understated by the following amounts: Current Current Period Cumulative Period Cumulative Obligation Obligation Expenditure Expenditure 2023 Q4 P&E Report $ 79,009 $ 89,009 $ 79,009 $ 89,009 2024 Q1 P&E Report 379,005 89,009 379,005 468,014 2024 Q2 P&E Report 1,331,499 79,009 1,331,499 468,014 2024 Q3 P&E Report 2,208,957 79,009 2,208,957 468,014 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 200.328 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." 31 CFR 35.4(c) states: "During the period of performance, recipients shall provide to the Secretary or her delegate, as applicable, periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary or her delegate, as applicable, may require for the administration of this section. In addition to regular reporting requirements, the Secretary may request other additional information as may be necessary or appropriate, including as may be necessary to prevent evasions of the requirements of this subpart. False statements or claims made to the Secretary may result in criminal, civil, or administrative sanctions, including fines, imprisonment, civil damages and penalties, debarment from participating in Federal awards or contracts, and/or any other remedy available by law." Cause The City's management did not have effective internal controls in place to ensure proper amounts were reported prior to submission. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of federal funding to the City. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the City strengthen its system of internal controls over the preparation and review of federal reports to ensure appropriate reviews, approvals, and oversight are effective in preventing, or detecting and correcting, noncompliance. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
U.S. Department of Health and Human Services Federal Financial Assistance Listing 93.423 1332 State Innovation Waivers Reporting Significant Deficiency in Internal Control in Federal Compliance Criteria: Recipients of federal funds must submit financial reports as required by the Federal award. Reports submitted annually by the recipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period, in accordance with CFR § 200.328(c). Condition: The Association’s existing controls over their reporting processes, to ensure reports were submitted timely, were not functioning in such a way that ensured reports were submitted on time. Cause: The Association didn’t set a reminder or have a pre-arranged schedule that notified management a report was due. Effect: 1 quarterly report was submitted 3 days late. 1 quarterly report was submitted 2 days late. Questioned Costs: None reported Context/Sampling: Sampling was not used. 100% of the reports submitted during the year were tested. Repeat Finding from Prior Year(s): No Recommendation: Management should have a control in place to ensure they are notified that a report is coming due so they are able to compile and submit it on time. If information required to be included in the report is not available at the time the report is due, management should have a control in place to request an extension for the delayed submission of the report. Views of Responsible Officials: Management of the Association agrees with the finding.
Department of Transportation Federal Financial Assistance Listing 20.106; Awards AIP3-46-0050-59, AIP3-46-0050-62, AIP3-46-0050-63, and AIP3-46-0050-64. COVID-19 Airport Improvement Program Reporting Material Weakness in Internal Control over Compliance; Material Noncompliance 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, 2024, for award AIP3-46-0050-64 underreported the federal share of expenditures by $23,588, while the FAA Form 5100-127 annual report dated December 31, 2023, for all awards underreported the total capital expenditures and construction in progress by $2,729,962. 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 7 reports out of 27 reports. Repeat Finding from Prior Year – Yes, prior year finding 2023-002 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 AIP3-46-0050-59, AIP3-46-0050-62, AIP3-46-0050-63, and AIP3-46-0050-64. COVID-19 Airport Improvement Program Reporting Material Weakness in Internal Control over Compliance; Material Noncompliance 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, 2024, for award AIP3-46-0050-64 underreported the federal share of expenditures by $23,588, while the FAA Form 5100-127 annual report dated December 31, 2023, for all awards underreported the total capital expenditures and construction in progress by $2,729,962. 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 7 reports out of 27 reports. Repeat Finding from Prior Year – Yes, prior year finding 2023-002 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 AIP3-46-0050-59, AIP3-46-0050-62, AIP3-46-0050-63, and AIP3-46-0050-64. COVID-19 Airport Improvement Program Reporting Material Weakness in Internal Control over Compliance; Material Noncompliance 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, 2024, for award AIP3-46-0050-64 underreported the federal share of expenditures by $23,588, while the FAA Form 5100-127 annual report dated December 31, 2023, for all awards underreported the total capital expenditures and construction in progress by $2,729,962. 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 7 reports out of 27 reports. Repeat Finding from Prior Year – Yes, prior year finding 2023-002 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 AIP3-46-0050-59, AIP3-46-0050-62, AIP3-46-0050-63, and AIP3-46-0050-64. COVID-19 Airport Improvement Program Reporting Material Weakness in Internal Control over Compliance; Material Noncompliance 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, 2024, for award AIP3-46-0050-64 underreported the federal share of expenditures by $23,588, while the FAA Form 5100-127 annual report dated December 31, 2023, for all awards underreported the total capital expenditures and construction in progress by $2,729,962. 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 7 reports out of 27 reports. Repeat Finding from Prior Year – Yes, prior year finding 2023-002 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.
Finding Number: 2024-001 Federal Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year: 2024 Assistance Listing Number (ALN): 21.027 Federal Awarding Agency: U.S. Department of Treasury Compliance Requirement: Reporting – Quarterly Program Reports Pass-through Entity: Ohio Department of Development Repeat Finding: No Significant Deficiency and Noncompliance – Timely Submission of Quarterly Program Reports Criteria: 2 C.F.R. § 200.328 Financial Reporting states, in part, the Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports. The recipient must submit quarterly program reports as required by the Federal award. In the Ohio Department of Development Water and Wastewater Infrastructure Program Grant Agreement, Statement of Agreement, Section 6 Reporting Requirements, Exhibit II Reporting, Section 2, Program Reports, all grant award recipients are required to submit program reports on a quarterly basis. Quarterly program reports must be submitted by close of business, on the second Friday, at the end of each quarter. Condition: The City did not submit the quarter ending December 31, 2024 Quarterly Program Report until March 7, 2025, after the deadline of January 10, 2025. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Auditor reviewed the Quarterly Program Report for period ending December 31, 2024 via email submission to Ohio Department of Development, and noted the City did not submit the report until March 7, 2025, which was after the deadline of January 10, 2025. These requirements are outlined in the federal award agreement and applicable UG provisions. Cause and Effect: The issue results of lack of monitoring control related to grant reporting requirements. Failure to submit reports as required, could result in non-compliance with grant requirements. Recommendation: We recommend that the City implement procedures and internal deadlines for reviewing and timely submitting all reports under federal awards. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2024-001 Federal Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year: 2024 Assistance Listing Number (ALN): 21.027 Federal Awarding Agency: U.S. Department of Treasury Compliance Requirement: Reporting – Quarterly Program Reports Pass-through Entity: Ohio Department of Development Repeat Finding: No Significant Deficiency and Noncompliance – Timely Submission of Quarterly Program Reports Criteria: 2 C.F.R. § 200.328 Financial Reporting states, in part, the Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports. The recipient must submit quarterly program reports as required by the Federal award. In the Ohio Department of Development Water and Wastewater Infrastructure Program Grant Agreement, Statement of Agreement, Section 6 Reporting Requirements, Exhibit II Reporting, Section 2, Program Reports, all grant award recipients are required to submit program reports on a quarterly basis. Quarterly program reports must be submitted by close of business, on the second Friday, at the end of each quarter. Condition: The City did not submit the quarter ending December 31, 2024 Quarterly Program Report until March 7, 2025, after the deadline of January 10, 2025. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Auditor reviewed the Quarterly Program Report for period ending December 31, 2024 via email submission to Ohio Department of Development, and noted the City did not submit the report until March 7, 2025, which was after the deadline of January 10, 2025. These requirements are outlined in the federal award agreement and applicable UG provisions. Cause and Effect: The issue results of lack of monitoring control related to grant reporting requirements. Failure to submit reports as required, could result in non-compliance with grant requirements. Recommendation: We recommend that the City implement procedures and internal deadlines for reviewing and timely submitting all reports under federal awards. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding: Reporting Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and COVID-19 Airports Programs Assistance Listing Number: 20.106 Department of Transportation, Award Number 3-05-0047-031-2023, Award Year 2023 Department of Transportation, Award Number 3-05-0047-032-2024, Award Year 2024 Criteria: In accordance with 2 CFR section 200.328, recipients must use the standard financial reporting forms when reporting to the federal awarding agency. Each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the federal awarding agency. Recipients use the Federal Financial Report (FFR) (SF-425/SF-425A) as a standardized format to report expenditures under federal awards, as well as, when applicable, cash status (lines 10.a, 10.b, and 10c). Condition: We noted the City did not complete and submit the required annual Federal Financial Reports (SF-425) for the two awards identified above during the year ended December 31, 2024. Questioned Costs: None Context: We identified and tested both FFR (SF-425) reports that were required to be completed and submitted for the year ended December 31, 2024, and noted the reports were not submitted as described above. Effect: Failure to complete and submit reports could lead to inaccurate reporting of information to the Federal Aviation Administration. In addition, failure to submit required reports to the Federal Aviation Administration could result in non-compliance and revocation of awarded grant funds. Cause: Controls over reporting were not sufficiently operating during the year primarily due to staffing issues and turnover within the Airport Department. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the City develop a process for reviewing and tracking the submission of FFR reporting to the Federal Aviation Administration. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.
Finding Number: 2024-001 Federal Program: COVID-19: SLFRF-Water and Wastewater Infrastructure Program Federal Award Identification Number and Year: DEV-2021-181504, DEV-2021-181549 Assistance Listing Number (ALN): 21.027 Federal Awarding Agency: Department of Treasury Pass-through Entity: Ohio Department of Development Repeat Finding: No Significant Deficiency and Noncompliance – Reporting Criteria: 2 C.F.R. § 200.328 Financial Reporting states, in part, the Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports. The recipient must submit quarterly program reports as required by the Federal award. In the Ohio Department of Development Water and Wastewater Infrastructure Program Grant Agreement, Statement of Agreement, Section 6 Reporting Requirements, Exhibit II Reporting, Section 2, Program Reports, all grant award recipients are required to submit program reports on a quarterly basis. Quarterly program reports must be submitted by close of business, on the second Friday, at the end of each quarter. In addition, the Ohio Department of Development Water and Wastewater Infrastructure Program Grant Agreement, Statement of Agreement Section 6 Reporting Requirements, Exhibit II Reporting, Section 1 states all financial reimbursement requests must be submitted electronically to the Grantor on a monthly basis as costs are incurred. Condition: The Conservancy District did not submit the required Program Report for the first quarter of 2024. In addition, federal financial reimbursement request for December 2023 activity was not submitted until February 2024. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Through testing of required reporting under terms and conditions of the federal award, we observed the Conservancy District did not meet required timeliness for financial and performance reporting. Specifically, one reimbursement request for costs incurred in December 2023 was delayed until February 2024. The required performance reporting for the first quarter of 2024 was not submitted. These requirements are outlined in the federal award agreement and applicable UG provisions. Cause and Effect: The issue results from a lack of monitoring control related to grant reporting requirements. Failure to submit reports as required, could result in noncompliance with grant requirements. Recommendation: We recommend management implement procedures and internal deadlines for reviewing and timely submitting all reports under federal awards. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.