Finding 2023-007 – Reporting (Significant Deficiency and Noncompliance) Information on the federal program: U.S. Department of Health and Human Services, Assistance Listing #93.137 Community Programs to Improve Minority Health Grant Program. Criteria: 2 CFR section 200.328 establishes the requirements for timely and accurate financial reporting requirements and 2 CFR 200.329 establishes responsibility for reporting activities under the grant. Both financial and programmatic reporting requires the nonfederal entity to establish internal controls to ensure accuracy of reports. Condition: We tested on financial and one programmatic report filed for this grant during the year. For the programmatic report, data reported for accomplishments and clients served was not clearly supported. In addition, review and approval of the report was not clearly documented. Cause: Results reported in the programmatic report were supported by time sheets and client internal notes. This support was not summarized or categorized in a manner in which the reported data could be traced back to the support. Employees involved in the preparing and filing of these reports are copied on email submission but a review and approval prior to submission was not documented. Effect: The Council did not comply with reporting control requirements. Questioned Costs: None reported Recommendation: We recommend the Council strengthen procedures and documentation policies to ensure program accomplishments are adequately supported by records that are accumulated and summarized in accordance with the required criteria. Procedures should also be strengthened to include a clear review and approval process to be documented prior to report submission. Views of Responsible Officials: See Management’s View and Corrective Action Plan at the end of the report.
Criteria: In accordance with 2 CFR §170, prime awardees awarded a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Further, the Organization is subject to reporting requirements for both financial and progress reporting. In accordance with 2 CFR §200.328, Federal Financial Reports (FFR) should be submitted based on frequency required by the terms and conditions. In instances were the Organization is a subrecipient, the grant agreement with the prime recipient Rural Community Assistance Partnership (RCAP), requires that in order to facilitate RCAP’s financial reporting requirements, the Organization is required to submit reimbursement request monthly within 10 days of the following month. Additionally, in accordance with the agreement with RCAP, in order to facilitate RCAP’s progress reporting requirements the Organization is required to submit data related to progress made within 12 days for quarterly reports under program 66.446 and a final narrative within 75 days from project close. The requirements for progress reports for program 10.761 are to be submitted within 15 days for quarterly reports and 45 days for final narrative. Condition: During the review of the reporting compliance requirement related to major program, it was determined that a FFATA reports were not filed by the Organization within the required period. Further, the Organization did not file a FFR report within the required deadline for a grant it is a prime recipient. For grants on which the Organization is a subrecipient, it was determined that reimbursement requests and progress reports were not submitted within the required deadline. Cause: Internal controls over financial reporting were not operating effectively to file the FFATA report a timely manner. Management was not aware of the FFATA requirements for prime awards. Further, internal controls over financial reporting were not operating effectively to file FFRs, reimbursement requests and progress reports in a timely manner. Effect: Failure to submit the FFATA reports by the end of the following month after sub-grant greater than $30,000 is awarded results in noncompliance with 2 CFR §170. Failure to submit the semi-annual FFR within the 30-day submission deadline results in noncompliance with 2 CFR §200.328. Additionally, failure to submit the reimbursement request and progress reports within the specified deadline results in a breach of contract with RCAP. Questioned Costs: Questioned costs were not identified.Perspective information: It is noted that the Organization has not established policies and procedures that will ensure that FFATA reports are submitted within the required timeline and therefore three out of three samples tested for this compliance requirement were not completed. Further, for the awards that the Organization was a prime recipient one out one sample tested from a population of two was submitted timely. For awards which the Organization is a subrecipient, three out of the nine samples tested from a population of thirty-six were not submitted within the specified timeline. Additionally, for awards which the Organization is a subrecipient, one out of two samples from a population of 12 were not submitted with the specified timeline. Non-compliance surrounding reporting was identified for the following awards during the fiscal 2023: Federal Agency Pass-Through Entity ALN Federal Award Name Award Year Department of Health and Human Services Direct 93.570 HHS RCD - SERCAP 9/30/2022 – 8/31/2023 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Technitrain 2022-2023 9/1/2022 – 8/31/2023 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Tribal 2022 - 2023 9/1/2022 – 8/31/2023 Environmental Protection Agency Rural Community Assistance Partnership Inc. 66.446 Training and Technical Assistance for Treatment Works 4/1/2022 – 9/30/2023 Repeat Finding: No similar finding was reported in the prior year. Recommendations: We recommend that management attend training related to federal grant requirements. We also recommend that management establish procedures to ensure that it meets FFATA requirements on a timely basis. The Organization should review its internal controls surrounding financial and progress reporting for each federal award and develop an effective reporting tracking system to allow the Organization to monitor and ensure reports are prepared and submitted within deadlines.
Criteria: In accordance with 2 CFR §170, prime awardees awarded a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Further, the Organization is subject to reporting requirements for both financial and progress reporting. In accordance with 2 CFR §200.328, Federal Financial Reports (FFR) should be submitted based on frequency required by the terms and conditions. In instances were the Organization is a subrecipient, the grant agreement with the prime recipient Rural Community Assistance Partnership (RCAP), requires that in order to facilitate RCAP’s financial reporting requirements, the Organization is required to submit reimbursement request monthly within 10 days of the following month. Additionally, in accordance with the agreement with RCAP, in order to facilitate RCAP’s progress reporting requirements the Organization is required to submit data related to progress made within 12 days for quarterly reports under program 66.446 and a final narrative within 75 days from project close. The requirements for progress reports for program 10.761 are to be submitted within 15 days for quarterly reports and 45 days for final narrative. Condition: During the review of the reporting compliance requirement related to major program, it was determined that a FFATA reports were not filed by the Organization within the required period. Further, the Organization did not file a FFR report within the required deadline for a grant it is a prime recipient. For grants on which the Organization is a subrecipient, it was determined that reimbursement requests and progress reports were not submitted within the required deadline. Cause: Internal controls over financial reporting were not operating effectively to file the FFATA report a timely manner. Management was not aware of the FFATA requirements for prime awards. Further, internal controls over financial reporting were not operating effectively to file FFRs, reimbursement requests and progress reports in a timely manner. Effect: Failure to submit the FFATA reports by the end of the following month after sub-grant greater than $30,000 is awarded results in noncompliance with 2 CFR §170. Failure to submit the semi-annual FFR within the 30-day submission deadline results in noncompliance with 2 CFR §200.328. Additionally, failure to submit the reimbursement request and progress reports within the specified deadline results in a breach of contract with RCAP. Questioned Costs: Questioned costs were not identified.Perspective information: It is noted that the Organization has not established policies and procedures that will ensure that FFATA reports are submitted within the required timeline and therefore three out of three samples tested for this compliance requirement were not completed. Further, for the awards that the Organization was a prime recipient one out one sample tested from a population of two was submitted timely. For awards which the Organization is a subrecipient, three out of the nine samples tested from a population of thirty-six were not submitted within the specified timeline. Additionally, for awards which the Organization is a subrecipient, one out of two samples from a population of 12 were not submitted with the specified timeline. Non-compliance surrounding reporting was identified for the following awards during the fiscal 2023: Federal Agency Pass-Through Entity ALN Federal Award Name Award Year Department of Health and Human Services Direct 93.570 HHS RCD - SERCAP 9/30/2022 – 8/31/2023 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Technitrain 2022-2023 9/1/2022 – 8/31/2023 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Tribal 2022 - 2023 9/1/2022 – 8/31/2023 Environmental Protection Agency Rural Community Assistance Partnership Inc. 66.446 Training and Technical Assistance for Treatment Works 4/1/2022 – 9/30/2023 Repeat Finding: No similar finding was reported in the prior year. Recommendations: We recommend that management attend training related to federal grant requirements. We also recommend that management establish procedures to ensure that it meets FFATA requirements on a timely basis. The Organization should review its internal controls surrounding financial and progress reporting for each federal award and develop an effective reporting tracking system to allow the Organization to monitor and ensure reports are prepared and submitted within deadlines.
Criteria: In accordance with 2 CFR §170, prime awardees awarded a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Further, the Organization is subject to reporting requirements for both financial and progress reporting. In accordance with 2 CFR §200.328, Federal Financial Reports (FFR) should be submitted based on frequency required by the terms and conditions. In instances were the Organization is a subrecipient, the grant agreement with the prime recipient Rural Community Assistance Partnership (RCAP), requires that in order to facilitate RCAP’s financial reporting requirements, the Organization is required to submit reimbursement request monthly within 10 days of the following month. Additionally, in accordance with the agreement with RCAP, in order to facilitate RCAP’s progress reporting requirements the Organization is required to submit data related to progress made within 12 days for quarterly reports under program 66.446 and a final narrative within 75 days from project close. The requirements for progress reports for program 10.761 are to be submitted within 15 days for quarterly reports and 45 days for final narrative. Condition: During the review of the reporting compliance requirement related to major program, it was determined that a FFATA reports were not filed by the Organization within the required period. Further, the Organization did not file a FFR report within the required deadline for a grant it is a prime recipient. For grants on which the Organization is a subrecipient, it was determined that reimbursement requests and progress reports were not submitted within the required deadline. Cause: Internal controls over financial reporting were not operating effectively to file the FFATA report a timely manner. Management was not aware of the FFATA requirements for prime awards. Further, internal controls over financial reporting were not operating effectively to file FFRs, reimbursement requests and progress reports in a timely manner. Effect: Failure to submit the FFATA reports by the end of the following month after sub-grant greater than $30,000 is awarded results in noncompliance with 2 CFR §170. Failure to submit the semi-annual FFR within the 30-day submission deadline results in noncompliance with 2 CFR §200.328. Additionally, failure to submit the reimbursement request and progress reports within the specified deadline results in a breach of contract with RCAP. Questioned Costs: Questioned costs were not identified.Perspective information: It is noted that the Organization has not established policies and procedures that will ensure that FFATA reports are submitted within the required timeline and therefore three out of three samples tested for this compliance requirement were not completed. Further, for the awards that the Organization was a prime recipient one out one sample tested from a population of two was submitted timely. For awards which the Organization is a subrecipient, three out of the nine samples tested from a population of thirty-six were not submitted within the specified timeline. Additionally, for awards which the Organization is a subrecipient, one out of two samples from a population of 12 were not submitted with the specified timeline. Non-compliance surrounding reporting was identified for the following awards during the fiscal 2023: Federal Agency Pass-Through Entity ALN Federal Award Name Award Year Department of Health and Human Services Direct 93.570 HHS RCD - SERCAP 9/30/2022 – 8/31/2023 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Technitrain 2022-2023 9/1/2022 – 8/31/2023 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Tribal 2022 - 2023 9/1/2022 – 8/31/2023 Environmental Protection Agency Rural Community Assistance Partnership Inc. 66.446 Training and Technical Assistance for Treatment Works 4/1/2022 – 9/30/2023 Repeat Finding: No similar finding was reported in the prior year. Recommendations: We recommend that management attend training related to federal grant requirements. We also recommend that management establish procedures to ensure that it meets FFATA requirements on a timely basis. The Organization should review its internal controls surrounding financial and progress reporting for each federal award and develop an effective reporting tracking system to allow the Organization to monitor and ensure reports are prepared and submitted within deadlines.
Item 2023‐003 Performance Reporting – Annual Project and Expenditure Report Coronavirus State and Local Fiscal Recovery Fund ALN# 21.027 U.S. Department of Treasury Grant period – Year ended September 30, 2023 Criteria – 2 CFR 200.303 requires the non‐Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” Grantees should have controls in place to ensure that required reporting requirements under the compliance supplement are satisfied. 2 CFR 200.328 requires the City to file the Annual Project and Expenditure Report under the Performance Reporting requirement of the grant. Condition – Adequate controls were not in place to ensure that annual reporting was filed in accordance with performance reporting requirements. Cause – Changes in leadership roles at the grantee led to a lack of sufficient controls over the communication of the reporting requirement to ensure the accuracy and completeness of performance reporting under the grant. Effect – Lack of notification of the reporting requirement could lead to disallowed costs. We noted that the annual report was subsequently submitted to the grantor. However, our audit disclosed no instances of unallowable costs. Questioned Costs – Not determinable. Recommendation – We recommend the strengthening of controls to ensure annual reporting required under the compliance supplement is performed in a timely manner. Management’s Response – The City will strengthen the controls in place to provide assurance that annual reporting is performed timely in accordance with program guidelines.
Finding 2023-003 Significant deficiency in internal controls over compliance related to reporting. Federal Agency: U.S. Department of Health and Human Services Program Title: Developmental Disabilities Basic Support and Advocacy Grants Assistance Listing Number: 93.630 Awards Number: 2201WAPADD-00 & 03; 2001WAPAPH-00 & 01 Award Period: 10/01/2021 - 9/30/2024 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subpart D section 2 CFR 200.328 (as codified by the Department of Health and Human Services [DHHS] in 45 CFR 75) requires accurate financial reporting to be submitted under the terms of the Federal award. Condition/Context For the year ended September 30, 2023, DRW submitted their required semi-annual SF-425 reporting for the reporting period ending September 30, 2023. Though the reporting was submitted timely, it contained inaccurate information related to the balance of their unused Program Income, excluding their unused balance of approximately $142,000. Effect/Potential Effect DRW did not comply with the accuracy reporting requirement as specific in 2 CFR 200.328 Questioned Costs Not applicable Cause DRW’s internal controls were not designed to ensure accurate reporting Repeat Finding Not applicable Recommendation We recommend that DRW implement internal controls to ensure required reporting includes accurate information. Views of Responsible Officials Management agrees with the finding and has provided the corrective action plan following the Single Audit Report.
Finding 2023-003 Significant deficiency in internal controls over compliance related to reporting. Federal Agency: U.S. Department of Health and Human Services Program Title: Developmental Disabilities Basic Support and Advocacy Grants Assistance Listing Number: 93.630 Awards Number: 2201WAPADD-00 & 03; 2001WAPAPH-00 & 01 Award Period: 10/01/2021 - 9/30/2024 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subpart D section 2 CFR 200.328 (as codified by the Department of Health and Human Services [DHHS] in 45 CFR 75) requires accurate financial reporting to be submitted under the terms of the Federal award. Condition/Context For the year ended September 30, 2023, DRW submitted their required semi-annual SF-425 reporting for the reporting period ending September 30, 2023. Though the reporting was submitted timely, it contained inaccurate information related to the balance of their unused Program Income, excluding their unused balance of approximately $142,000. Effect/Potential Effect DRW did not comply with the accuracy reporting requirement as specific in 2 CFR 200.328 Questioned Costs Not applicable Cause DRW’s internal controls were not designed to ensure accurate reporting Repeat Finding Not applicable Recommendation We recommend that DRW implement internal controls to ensure required reporting includes accurate information. Views of Responsible Officials Management agrees with the finding and has provided the corrective action plan following the Single Audit Report.
Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Assistance Listing Number: 21.027 Compliance Requirement: Reporting Federal Agency: Department of Treasury Criteria or Specific Requirement: In accordance with the Authoritative Requirement 2 CFR 200.328, 31 CFR section 35.4(c) Reporting and request for other information, and the Consolidated Appropriations Act, (CAA), grantees using SLFRF funds for the eligible uses provided in the 2023 CAA will be required to report on their uses of funds in their Project and Expenditure reports. Condition: Required submission of the Project and Expenditure report during fiscal year 2023 was not submitted prior to the reporting deadline. Questioned Costs: None Context: The City’s Project and Expenditure report was selected for testing and it was noted the City did not submit the required report prior to the reporting deadline. Effect: The City did not submit the required Project and Expenditure report by the reporting deadline as required by the Uniform Guidance. Cause: The City did not have adequate internal controls over reporting requirements to ensure that the required report was submitted prior to the reporting deadline. Identification as a Repeat Finding: N/A Recommendation: Management should implement policies and procedures to ensure required reports are completed and filed by their respective due date in accordance with the grant agreement and the Uniform Guidance. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.
Criteria or Specific Requirement 2 CFR 200.328 and 31 CFR section 35.4(c) requires submission of quarterly and annual project and expenditure reports which are due to the Department of Treasury 30 days after the end of each quarter and April 30th, of the year proceeding, respectively. The project and expenditure report contains specific instructions on how to complete the report. Within the project and expenditure report, ‘Expenditure Categories’ is a critical component to be completed by reporting “obligations” and “expenditures” on each project. As defined in the report, “obligation” is an order placed (such as a contract) and similar transactions that require payment; “expenditure” is when the service has been rendered or the good has been delivered to the entity, and payment is due. Condition Upon review and testing of the quarterly reports as submitted to the Department of Treasury, it was noted that amounts reported as expenditures for certain projects included amounts that were obligated but not yet incurred (service was not yet rendered or the good was not yet received) until a subsequent quarter. The expenditures as reported were allowable expenditures, but the timing of the expenditures was reported in the incorrect period. In addition, upon testing the expenditures as reported in the unadjusted schedule of expenditures of federal awards (the “schedule”), it was noted that $415,821 was improperly included as expenditures belonging to the fiscal year ended September 30, 2023. The expenditures identified were prematurely recorded in the general ledger since the equipment was not received until after year-end. The City’s schedule of expenditures of federal awards for the fiscal year ended September 30, 2023 required a correction to remove those amounts from the schedule and to add those amounts to the subsequent fiscal year’s schedule. Cause The Grants Administrator’s lack of understanding of the proper manner in which the obligations and expenditures are required to be reported in the quarterly reports resulted in expenditure amounts being reported in the incorrect quarters. The City’s year-end procedures did not identify certain necessary adjustments in a timely manner in order to remove capital outlay expenditures that were incorrectly recorded during the fiscal year ended September 30, 2023 and were incorrectly included in the unadjusted schedule of expenditures of federal awards. The Grants Administrator utilized the amounts recorded as expenditures in the accounting system to prepare the quarterly reports. Expenditures should be recorded in the City’s general ledger utilizing the date services are rendered and/or goods are received. Proper monthly review of the expenditure accounts should have led to identifying expenditures that were recorded but not yet incurred. Effect or Potential Effect The two conditions listed above resulted in differences between expenditure amounts as correctly adjusted and reported in the schedule of expenditures of federal awards, versus expenditure amounts as reported and submitted to the Department of Treasury in the quarterly reports. Future reports may be incorrectly completed if obligation amounts and expenditure amounts are not following the criteria to properly enter amounts in the quarterly reports. Questioned Costs None. Context During compliance testing of the reporting compliance requirement, it was noted that the total expenditures included in the schedule of expenditures of federal awards for the fiscal year ended September 30, 2023 did not agree to the total expenditures reported in the quarterly expenditure reports as submitted to the Department of Treasury for the same period. During testing of disbursements as included in the schedule of expenditures of federal awards for the major Federal program, and during internal control and compliance testing, it was noted there were two disbursements, amounting to a total of $415,821, recorded within accounts payable as capital outlay expenditures which were improperly recorded in the fiscal year ended September 30, 2023 and improperly included in the schedule of expenditures of federal awards. As evidenced by the invoice date and ship date within the invoices, the equipment was not shipped, and the equipment was not received by the City, until after year-end. The expenditures should be recorded and reported in the fiscal year ended September 30, 2023. Adjustments were made accordingly for proper recording, reporting, and presentation in the financial statements and schedule of expenditures of federal awards. Repeat Finding This is a variation of a prior year finding from 2022. See summary schedule of prior audit findings. Recommendation Management should ensure year-end closing procedures are completed in a timely manner and are sufficient to assure accounts and financial statements are prepared in accordance with GAAP. If properly prepared and recorded, the subledgers for expenditures by federal awards will be generated with accurate expenditure amounts for the fiscal year. Management should assess the risk associated with this condition and identify any additional processes that can be incorporated into their existing controls to improve the deficiency; such as, minimizing the likelihood of year-end material audit adjustments through review of transactions and balances for general propriety and accuracy within one month after year-end. Follow-up and inquiries can be made timely for any transactions for which proper recording is unclear to management, if any. The Grants Administrator should maintain an up-to-date listing of expenditures by award (for all federal, state, and local awards) and should communicate with the Finance Department on a monthly basis to review the listing and determine the proper period in which the expenditures should be recorded and presented. The Grants Administrator and Finance Department should prepare a reconciliation of the expenditures as reported in the schedule of expenditures of federal awards for the major Federal program for the fiscal year ended September 30, 2023, as well as expenditures incurred from October 1, 2023 through today, and compare to the expenditures as reported in all quarterly reports through September 30, 2023 and September 30, 2024. An analysis should be completed to determine the differences between the expenditures incurred by quarter versus expenditures as reported by quarter, and to determine the differences in total between expenditures incurred and expenditures reported in the quarterly and annual project and expenditure reports. The Grants Administrator should then review the Department of Treasury’s Project and Expenditure Report User Guide of State and Local Fiscal Recovery Funds, and/or contact the grantor, to determine if reports as previously submitted should be corrected for the timing difference, or to determine what the correct course of action should be.
Finding 2023-005 – REPORTING Type: Material Weakness in Internal Control/Noncompliance. Program: ALN 93.493 Congressional Directives Criteria: Pursuant to 2 CFR 200.328(c), “The recipient or subrecipient must submit financial reports as required by the Federal award.” According to the closeout requirements of the Federal award, recipients must, “Reconcile financial expenditures to the reported total disbursement and charges in PMS.” Condition: The CMHSP did not reconcile financial expenditures shown in the Federal Financial Report to the total disbursement and charges in PMS. Cause: This condition was caused by an insufficient internal control process for review and approval of grant reports. Effect: Federal share of expenditures listed on the Federal Financial Report were overstated by $361,981. Questioned Cost: None. Context: Amounts received as Federal reimbursement, as detailed in PMS, were supported by the books and records of the CMHSP. However, the final report of expenditures was overstated by $361,981. Recommendation: We recommend that the CMHSP review their internal controls and make necessary changes to ensure that reports adhere to the grant requirements. Management’s Resp: We are in agreement with this finding.
Finding 2023-004 – Reporting (Significant Deficiency and Noncompliance) Information on the federal program: U.S. Department of Education, Assistance listing # 84.425 Education Stabilization Fund Criteria: 2 CFR 200.328-300 establish requirements for designing and monitoring internal controls over reporting requirements of a non-federal entity. Controls should be implemented to ensure accurate and complete reporting compliance. Condition: We selected a sample of 2 reports submitted for the HEERF program during the year. For both the annual and quarterly report examined, there was no documentation of a control such as reviewing and approving the report prior to submission. In addition, the annual report programmatic data source documentation varied from the data reported for several items. Cause: The College had a team managing the COVID funds due to their unique nature. While they were contact with each other about the program and reports, documentation of a review and approval was not available. The annual report included programmatic accomplishments and the report provided to support the data had several variances. Effect: The College did not properly implement documentation of internal controls to ensure compliance with reporting requirements. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures surrounding grant reporting to include documentation of controls such as review and approvals to ensure documentation is retained to support compliance requirements. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Information on the federal program: U.S. Department of the Treasury, Assistance listing # 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Criteria: 2 CFR 200.328-300 establish requirements for designing and monitoring internal controls over reporting requirements of a non-federal entity. Controls should be implemented to ensure accurate and complete reporting compliance. The Coronavirus State and Local Fiscal Recovery Funds: Overview of the Final Rule establishes the specific requirements for ARPA fund reporting. Condition: We examined the annual Project and Expenditure report required. It was not filed within 30 days of specified year end as required. Cause: There had been no fund expenditures prior to December of 2022. Annual reporting requirements for ARPA funds is at March 30 year end. The City’s controls around reporting focus on fiscal quarter end and fiscal and calendar year end. This reporting period is not in the City’s normal reporting schedule and therefore was not addressed through the controls in place. Effect: The City did not timely fulfill the related reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures surrounding grant reporting to include (at inception of each award) documentation of a schedule of reporting requirements, review, and approvals to ensure documentation is retained to support compliance requirements. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan included at the end of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
2023-004 U.S. Department of Transportation Federal Financial Assistance Listing 20.106 Airport Improvement Grant 3-16-0018-048-2020, 3-16-0018-049-2021, 3-16-0018-054-2021, 3-16-0018-055-2021, 3-16-0018-056-2022 Compliance Requirement - Reporting Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR §200.328, Financial Reporting, mandates that 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. Condition: During our testing of the required annual reports, SF-425 report, it was noted some of the annual reports required to be submitted by December 31, 2022, were submitted late on January 3, 2023. Cause: During the period under audit, there was a changeover in personnel at the airport, including the individual who was responsible for reviewing and submitting the reports. Effect: The reports were submitted to and accepted by the FAA; however, they were late. Questioned Costs: None reported. Context/Sampling: Sampling was not used. 100% of the required reports were tested. Of the 11 reports required to be submitted by December 31, 2022, 5 of them were late. Repeat Finding from Prior Year(s): Yes, 2022-001 Recommendation: The City should review its current policies and processes to ensure that the controls operate effectively, even in the event of a change in personnel. Views of Responsible Officials: The City concurs with the auditor’s findings.
2023-004 U.S. Department of Transportation Federal Financial Assistance Listing 20.106 Airport Improvement Grant 3-16-0018-048-2020, 3-16-0018-049-2021, 3-16-0018-054-2021, 3-16-0018-055-2021, 3-16-0018-056-2022 Compliance Requirement - Reporting Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR §200.328, Financial Reporting, mandates that 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. Condition: During our testing of the required annual reports, SF-425 report, it was noted some of the annual reports required to be submitted by December 31, 2022, were submitted late on January 3, 2023. Cause: During the period under audit, there was a changeover in personnel at the airport, including the individual who was responsible for reviewing and submitting the reports. Effect: The reports were submitted to and accepted by the FAA; however, they were late. Questioned Costs: None reported. Context/Sampling: Sampling was not used. 100% of the required reports were tested. Of the 11 reports required to be submitted by December 31, 2022, 5 of them were late. Repeat Finding from Prior Year(s): Yes, 2022-001 Recommendation: The City should review its current policies and processes to ensure that the controls operate effectively, even in the event of a change in personnel. Views of Responsible Officials: The City concurs with the auditor’s findings.
2023-004 U.S. Department of Transportation Federal Financial Assistance Listing 20.106 Airport Improvement Grant 3-16-0018-048-2020, 3-16-0018-049-2021, 3-16-0018-054-2021, 3-16-0018-055-2021, 3-16-0018-056-2022 Compliance Requirement - Reporting Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR §200.328, Financial Reporting, mandates that 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. Condition: During our testing of the required annual reports, SF-425 report, it was noted some of the annual reports required to be submitted by December 31, 2022, were submitted late on January 3, 2023. Cause: During the period under audit, there was a changeover in personnel at the airport, including the individual who was responsible for reviewing and submitting the reports. Effect: The reports were submitted to and accepted by the FAA; however, they were late. Questioned Costs: None reported. Context/Sampling: Sampling was not used. 100% of the required reports were tested. Of the 11 reports required to be submitted by December 31, 2022, 5 of them were late. Repeat Finding from Prior Year(s): Yes, 2022-001 Recommendation: The City should review its current policies and processes to ensure that the controls operate effectively, even in the event of a change in personnel. Views of Responsible Officials: The City concurs with the auditor’s findings.
2023-004 U.S. Department of Transportation Federal Financial Assistance Listing 20.106 Airport Improvement Grant 3-16-0018-048-2020, 3-16-0018-049-2021, 3-16-0018-054-2021, 3-16-0018-055-2021, 3-16-0018-056-2022 Compliance Requirement - Reporting Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR §200.328, Financial Reporting, mandates that 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. Condition: During our testing of the required annual reports, SF-425 report, it was noted some of the annual reports required to be submitted by December 31, 2022, were submitted late on January 3, 2023. Cause: During the period under audit, there was a changeover in personnel at the airport, including the individual who was responsible for reviewing and submitting the reports. Effect: The reports were submitted to and accepted by the FAA; however, they were late. Questioned Costs: None reported. Context/Sampling: Sampling was not used. 100% of the required reports were tested. Of the 11 reports required to be submitted by December 31, 2022, 5 of them were late. Repeat Finding from Prior Year(s): Yes, 2022-001 Recommendation: The City should review its current policies and processes to ensure that the controls operate effectively, even in the event of a change in personnel. Views of Responsible Officials: The City concurs with the auditor’s findings.
2023-004 U.S. Department of Transportation Federal Financial Assistance Listing 20.106 Airport Improvement Grant 3-16-0018-048-2020, 3-16-0018-049-2021, 3-16-0018-054-2021, 3-16-0018-055-2021, 3-16-0018-056-2022 Compliance Requirement - Reporting Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR §200.328, Financial Reporting, mandates that 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. Condition: During our testing of the required annual reports, SF-425 report, it was noted some of the annual reports required to be submitted by December 31, 2022, were submitted late on January 3, 2023. Cause: During the period under audit, there was a changeover in personnel at the airport, including the individual who was responsible for reviewing and submitting the reports. Effect: The reports were submitted to and accepted by the FAA; however, they were late. Questioned Costs: None reported. Context/Sampling: Sampling was not used. 100% of the required reports were tested. Of the 11 reports required to be submitted by December 31, 2022, 5 of them were late. Repeat Finding from Prior Year(s): Yes, 2022-001 Recommendation: The City should review its current policies and processes to ensure that the controls operate effectively, even in the event of a change in personnel. Views of Responsible Officials: The City concurs with the auditor’s findings.
2023-004 U.S. Department of Transportation Federal Financial Assistance Listing 20.106 Airport Improvement Grant 3-16-0018-048-2020, 3-16-0018-049-2021, 3-16-0018-054-2021, 3-16-0018-055-2021, 3-16-0018-056-2022 Compliance Requirement - Reporting Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR §200.328, Financial Reporting, mandates that 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. Condition: During our testing of the required annual reports, SF-425 report, it was noted some of the annual reports required to be submitted by December 31, 2022, were submitted late on January 3, 2023. Cause: During the period under audit, there was a changeover in personnel at the airport, including the individual who was responsible for reviewing and submitting the reports. Effect: The reports were submitted to and accepted by the FAA; however, they were late. Questioned Costs: None reported. Context/Sampling: Sampling was not used. 100% of the required reports were tested. Of the 11 reports required to be submitted by December 31, 2022, 5 of them were late. Repeat Finding from Prior Year(s): Yes, 2022-001 Recommendation: The City should review its current policies and processes to ensure that the controls operate effectively, even in the event of a change in personnel. Views of Responsible Officials: The City concurs with the auditor’s findings.
2023-004 U.S. Department of Transportation Federal Financial Assistance Listing 20.106 Airport Improvement Grant 3-16-0018-048-2020, 3-16-0018-049-2021, 3-16-0018-054-2021, 3-16-0018-055-2021, 3-16-0018-056-2022 Compliance Requirement - Reporting Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR §200.328, Financial Reporting, mandates that 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. Condition: During our testing of the required annual reports, SF-425 report, it was noted some of the annual reports required to be submitted by December 31, 2022, were submitted late on January 3, 2023. Cause: During the period under audit, there was a changeover in personnel at the airport, including the individual who was responsible for reviewing and submitting the reports. Effect: The reports were submitted to and accepted by the FAA; however, they were late. Questioned Costs: None reported. Context/Sampling: Sampling was not used. 100% of the required reports were tested. Of the 11 reports required to be submitted by December 31, 2022, 5 of them were late. Repeat Finding from Prior Year(s): Yes, 2022-001 Recommendation: The City should review its current policies and processes to ensure that the controls operate effectively, even in the event of a change in personnel. Views of Responsible Officials: The City concurs with the auditor’s findings.
2023-004 U.S. Department of Transportation Federal Financial Assistance Listing 20.106 Airport Improvement Grant 3-16-0018-048-2020, 3-16-0018-049-2021, 3-16-0018-054-2021, 3-16-0018-055-2021, 3-16-0018-056-2022 Compliance Requirement - Reporting Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR §200.328, Financial Reporting, mandates that 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. Condition: During our testing of the required annual reports, SF-425 report, it was noted some of the annual reports required to be submitted by December 31, 2022, were submitted late on January 3, 2023. Cause: During the period under audit, there was a changeover in personnel at the airport, including the individual who was responsible for reviewing and submitting the reports. Effect: The reports were submitted to and accepted by the FAA; however, they were late. Questioned Costs: None reported. Context/Sampling: Sampling was not used. 100% of the required reports were tested. Of the 11 reports required to be submitted by December 31, 2022, 5 of them were late. Repeat Finding from Prior Year(s): Yes, 2022-001 Recommendation: The City should review its current policies and processes to ensure that the controls operate effectively, even in the event of a change in personnel. Views of Responsible Officials: The City concurs with the auditor’s findings.
2023-004 U.S. Department of Transportation Federal Financial Assistance Listing 20.106 Airport Improvement Grant 3-16-0018-048-2020, 3-16-0018-049-2021, 3-16-0018-054-2021, 3-16-0018-055-2021, 3-16-0018-056-2022 Compliance Requirement - Reporting Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR §200.328, Financial Reporting, mandates that 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. Condition: During our testing of the required annual reports, SF-425 report, it was noted some of the annual reports required to be submitted by December 31, 2022, were submitted late on January 3, 2023. Cause: During the period under audit, there was a changeover in personnel at the airport, including the individual who was responsible for reviewing and submitting the reports. Effect: The reports were submitted to and accepted by the FAA; however, they were late. Questioned Costs: None reported. Context/Sampling: Sampling was not used. 100% of the required reports were tested. Of the 11 reports required to be submitted by December 31, 2022, 5 of them were late. Repeat Finding from Prior Year(s): Yes, 2022-001 Recommendation: The City should review its current policies and processes to ensure that the controls operate effectively, even in the event of a change in personnel. Views of Responsible Officials: The City concurs with the auditor’s findings.
2023-004 U.S. Department of Transportation Federal Financial Assistance Listing 20.106 Airport Improvement Grant 3-16-0018-048-2020, 3-16-0018-049-2021, 3-16-0018-054-2021, 3-16-0018-055-2021, 3-16-0018-056-2022 Compliance Requirement - Reporting Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR §200.328, Financial Reporting, mandates that 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. Condition: During our testing of the required annual reports, SF-425 report, it was noted some of the annual reports required to be submitted by December 31, 2022, were submitted late on January 3, 2023. Cause: During the period under audit, there was a changeover in personnel at the airport, including the individual who was responsible for reviewing and submitting the reports. Effect: The reports were submitted to and accepted by the FAA; however, they were late. Questioned Costs: None reported. Context/Sampling: Sampling was not used. 100% of the required reports were tested. Of the 11 reports required to be submitted by December 31, 2022, 5 of them were late. Repeat Finding from Prior Year(s): Yes, 2022-001 Recommendation: The City should review its current policies and processes to ensure that the controls operate effectively, even in the event of a change in personnel. Views of Responsible Officials: The City concurs with the auditor’s findings.
2023-001 L Reporting Compliance Requirement (Significant Deficiency in Internal Controls over Compliance and Noncompliance) Reference Number: 2023-001 L. Reporting Compliance Requirement ALN 21.027 Coronavirus State and Local Fiscal Recovery Fund Federal Award Agreement Number: 17460025442 Award Year: 2022-2023 Federal Agency: U.S. Department of Treasury Criteria: Non‐federal entities are required to establish and maintain effective internal controls over compliance in accordance with 2 CFR 200.328 and 31 CFR section 35.4 (c), states metropolitan cities and counties with a population below 250,000 residents that are allocated more than $10 million in SLFRF funding are required to submit quarterly Project and Expenditure Reports. Condition Found: During our review of the quarterly reporting process, CRI identified one quarterly report was not submitted and no documentation was maintained to support evidence that the report was reviewed and submitted. Cause: Documentation regarding Q1 2023 project and expenditure report was not maintained. Effect: The Department of Treasury uses the reports internally for oversight purposes and to fulfill Treasury’s transparency and legal obligations. The results of the City not submitting a report timely could lead to a finding of non‐compliance, which could result in development of corrective action plan or other consequences. Questioned Cost: $0 Recommendation: We recommend the City to document and maintain all quarterly reports that are submitted through the portal and include a printout of all reports submitted. Views of Responsible Officials: Management agrees with the findings. See corrective action plan beginning on page 228.
Finding 2023-007 – Reporting (Significant Deficiency and Noncompliance) Information on the federal program: U.S. Department of Health and Human Services, Assistance Listing #93.137 Community Programs to Improve Minority Health Grant Program. Criteria: 2 CFR section 200.328 establishes the requirements for timely and accurate financial reporting requirements and 2 CFR 200.329 establishes responsibility for reporting activities under the grant. Both financial and programmatic reporting requires the nonfederal entity to establish internal controls to ensure accuracy of reports. Condition: We tested on financial and one programmatic report filed for this grant during the year. For the programmatic report, data reported for accomplishments and clients served was not clearly supported. In addition, review and approval of the report was not clearly documented. Cause: Results reported in the programmatic report were supported by time sheets and client internal notes. This support was not summarized or categorized in a manner in which the reported data could be traced back to the support. Employees involved in the preparing and filing of these reports are copied on email submission but a review and approval prior to submission was not documented. Effect: The Council did not comply with reporting control requirements. Questioned Costs: None reported Recommendation: We recommend the Council strengthen procedures and documentation policies to ensure program accomplishments are adequately supported by records that are accumulated and summarized in accordance with the required criteria. Procedures should also be strengthened to include a clear review and approval process to be documented prior to report submission. Views of Responsible Officials: See Management’s View and Corrective Action Plan at the end of the report.
Criteria: In accordance with 2 CFR §170, prime awardees awarded a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Further, the Organization is subject to reporting requirements for both financial and progress reporting. In accordance with 2 CFR §200.328, Federal Financial Reports (FFR) should be submitted based on frequency required by the terms and conditions. In instances were the Organization is a subrecipient, the grant agreement with the prime recipient Rural Community Assistance Partnership (RCAP), requires that in order to facilitate RCAP’s financial reporting requirements, the Organization is required to submit reimbursement request monthly within 10 days of the following month. Additionally, in accordance with the agreement with RCAP, in order to facilitate RCAP’s progress reporting requirements the Organization is required to submit data related to progress made within 12 days for quarterly reports under program 66.446 and a final narrative within 75 days from project close. The requirements for progress reports for program 10.761 are to be submitted within 15 days for quarterly reports and 45 days for final narrative. Condition: During the review of the reporting compliance requirement related to major program, it was determined that a FFATA reports were not filed by the Organization within the required period. Further, the Organization did not file a FFR report within the required deadline for a grant it is a prime recipient. For grants on which the Organization is a subrecipient, it was determined that reimbursement requests and progress reports were not submitted within the required deadline. Cause: Internal controls over financial reporting were not operating effectively to file the FFATA report a timely manner. Management was not aware of the FFATA requirements for prime awards. Further, internal controls over financial reporting were not operating effectively to file FFRs, reimbursement requests and progress reports in a timely manner. Effect: Failure to submit the FFATA reports by the end of the following month after sub-grant greater than $30,000 is awarded results in noncompliance with 2 CFR §170. Failure to submit the semi-annual FFR within the 30-day submission deadline results in noncompliance with 2 CFR §200.328. Additionally, failure to submit the reimbursement request and progress reports within the specified deadline results in a breach of contract with RCAP. Questioned Costs: Questioned costs were not identified.Perspective information: It is noted that the Organization has not established policies and procedures that will ensure that FFATA reports are submitted within the required timeline and therefore three out of three samples tested for this compliance requirement were not completed. Further, for the awards that the Organization was a prime recipient one out one sample tested from a population of two was submitted timely. For awards which the Organization is a subrecipient, three out of the nine samples tested from a population of thirty-six were not submitted within the specified timeline. Additionally, for awards which the Organization is a subrecipient, one out of two samples from a population of 12 were not submitted with the specified timeline. Non-compliance surrounding reporting was identified for the following awards during the fiscal 2023: Federal Agency Pass-Through Entity ALN Federal Award Name Award Year Department of Health and Human Services Direct 93.570 HHS RCD - SERCAP 9/30/2022 – 8/31/2023 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Technitrain 2022-2023 9/1/2022 – 8/31/2023 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Tribal 2022 - 2023 9/1/2022 – 8/31/2023 Environmental Protection Agency Rural Community Assistance Partnership Inc. 66.446 Training and Technical Assistance for Treatment Works 4/1/2022 – 9/30/2023 Repeat Finding: No similar finding was reported in the prior year. Recommendations: We recommend that management attend training related to federal grant requirements. We also recommend that management establish procedures to ensure that it meets FFATA requirements on a timely basis. The Organization should review its internal controls surrounding financial and progress reporting for each federal award and develop an effective reporting tracking system to allow the Organization to monitor and ensure reports are prepared and submitted within deadlines.
Criteria: In accordance with 2 CFR §170, prime awardees awarded a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Further, the Organization is subject to reporting requirements for both financial and progress reporting. In accordance with 2 CFR §200.328, Federal Financial Reports (FFR) should be submitted based on frequency required by the terms and conditions. In instances were the Organization is a subrecipient, the grant agreement with the prime recipient Rural Community Assistance Partnership (RCAP), requires that in order to facilitate RCAP’s financial reporting requirements, the Organization is required to submit reimbursement request monthly within 10 days of the following month. Additionally, in accordance with the agreement with RCAP, in order to facilitate RCAP’s progress reporting requirements the Organization is required to submit data related to progress made within 12 days for quarterly reports under program 66.446 and a final narrative within 75 days from project close. The requirements for progress reports for program 10.761 are to be submitted within 15 days for quarterly reports and 45 days for final narrative. Condition: During the review of the reporting compliance requirement related to major program, it was determined that a FFATA reports were not filed by the Organization within the required period. Further, the Organization did not file a FFR report within the required deadline for a grant it is a prime recipient. For grants on which the Organization is a subrecipient, it was determined that reimbursement requests and progress reports were not submitted within the required deadline. Cause: Internal controls over financial reporting were not operating effectively to file the FFATA report a timely manner. Management was not aware of the FFATA requirements for prime awards. Further, internal controls over financial reporting were not operating effectively to file FFRs, reimbursement requests and progress reports in a timely manner. Effect: Failure to submit the FFATA reports by the end of the following month after sub-grant greater than $30,000 is awarded results in noncompliance with 2 CFR §170. Failure to submit the semi-annual FFR within the 30-day submission deadline results in noncompliance with 2 CFR §200.328. Additionally, failure to submit the reimbursement request and progress reports within the specified deadline results in a breach of contract with RCAP. Questioned Costs: Questioned costs were not identified.Perspective information: It is noted that the Organization has not established policies and procedures that will ensure that FFATA reports are submitted within the required timeline and therefore three out of three samples tested for this compliance requirement were not completed. Further, for the awards that the Organization was a prime recipient one out one sample tested from a population of two was submitted timely. For awards which the Organization is a subrecipient, three out of the nine samples tested from a population of thirty-six were not submitted within the specified timeline. Additionally, for awards which the Organization is a subrecipient, one out of two samples from a population of 12 were not submitted with the specified timeline. Non-compliance surrounding reporting was identified for the following awards during the fiscal 2023: Federal Agency Pass-Through Entity ALN Federal Award Name Award Year Department of Health and Human Services Direct 93.570 HHS RCD - SERCAP 9/30/2022 – 8/31/2023 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Technitrain 2022-2023 9/1/2022 – 8/31/2023 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Tribal 2022 - 2023 9/1/2022 – 8/31/2023 Environmental Protection Agency Rural Community Assistance Partnership Inc. 66.446 Training and Technical Assistance for Treatment Works 4/1/2022 – 9/30/2023 Repeat Finding: No similar finding was reported in the prior year. Recommendations: We recommend that management attend training related to federal grant requirements. We also recommend that management establish procedures to ensure that it meets FFATA requirements on a timely basis. The Organization should review its internal controls surrounding financial and progress reporting for each federal award and develop an effective reporting tracking system to allow the Organization to monitor and ensure reports are prepared and submitted within deadlines.
Criteria: In accordance with 2 CFR §170, prime awardees awarded a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Further, the Organization is subject to reporting requirements for both financial and progress reporting. In accordance with 2 CFR §200.328, Federal Financial Reports (FFR) should be submitted based on frequency required by the terms and conditions. In instances were the Organization is a subrecipient, the grant agreement with the prime recipient Rural Community Assistance Partnership (RCAP), requires that in order to facilitate RCAP’s financial reporting requirements, the Organization is required to submit reimbursement request monthly within 10 days of the following month. Additionally, in accordance with the agreement with RCAP, in order to facilitate RCAP’s progress reporting requirements the Organization is required to submit data related to progress made within 12 days for quarterly reports under program 66.446 and a final narrative within 75 days from project close. The requirements for progress reports for program 10.761 are to be submitted within 15 days for quarterly reports and 45 days for final narrative. Condition: During the review of the reporting compliance requirement related to major program, it was determined that a FFATA reports were not filed by the Organization within the required period. Further, the Organization did not file a FFR report within the required deadline for a grant it is a prime recipient. For grants on which the Organization is a subrecipient, it was determined that reimbursement requests and progress reports were not submitted within the required deadline. Cause: Internal controls over financial reporting were not operating effectively to file the FFATA report a timely manner. Management was not aware of the FFATA requirements for prime awards. Further, internal controls over financial reporting were not operating effectively to file FFRs, reimbursement requests and progress reports in a timely manner. Effect: Failure to submit the FFATA reports by the end of the following month after sub-grant greater than $30,000 is awarded results in noncompliance with 2 CFR §170. Failure to submit the semi-annual FFR within the 30-day submission deadline results in noncompliance with 2 CFR §200.328. Additionally, failure to submit the reimbursement request and progress reports within the specified deadline results in a breach of contract with RCAP. Questioned Costs: Questioned costs were not identified.Perspective information: It is noted that the Organization has not established policies and procedures that will ensure that FFATA reports are submitted within the required timeline and therefore three out of three samples tested for this compliance requirement were not completed. Further, for the awards that the Organization was a prime recipient one out one sample tested from a population of two was submitted timely. For awards which the Organization is a subrecipient, three out of the nine samples tested from a population of thirty-six were not submitted within the specified timeline. Additionally, for awards which the Organization is a subrecipient, one out of two samples from a population of 12 were not submitted with the specified timeline. Non-compliance surrounding reporting was identified for the following awards during the fiscal 2023: Federal Agency Pass-Through Entity ALN Federal Award Name Award Year Department of Health and Human Services Direct 93.570 HHS RCD - SERCAP 9/30/2022 – 8/31/2023 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Technitrain 2022-2023 9/1/2022 – 8/31/2023 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Tribal 2022 - 2023 9/1/2022 – 8/31/2023 Environmental Protection Agency Rural Community Assistance Partnership Inc. 66.446 Training and Technical Assistance for Treatment Works 4/1/2022 – 9/30/2023 Repeat Finding: No similar finding was reported in the prior year. Recommendations: We recommend that management attend training related to federal grant requirements. We also recommend that management establish procedures to ensure that it meets FFATA requirements on a timely basis. The Organization should review its internal controls surrounding financial and progress reporting for each federal award and develop an effective reporting tracking system to allow the Organization to monitor and ensure reports are prepared and submitted within deadlines.
Item 2023‐003 Performance Reporting – Annual Project and Expenditure Report Coronavirus State and Local Fiscal Recovery Fund ALN# 21.027 U.S. Department of Treasury Grant period – Year ended September 30, 2023 Criteria – 2 CFR 200.303 requires the non‐Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” Grantees should have controls in place to ensure that required reporting requirements under the compliance supplement are satisfied. 2 CFR 200.328 requires the City to file the Annual Project and Expenditure Report under the Performance Reporting requirement of the grant. Condition – Adequate controls were not in place to ensure that annual reporting was filed in accordance with performance reporting requirements. Cause – Changes in leadership roles at the grantee led to a lack of sufficient controls over the communication of the reporting requirement to ensure the accuracy and completeness of performance reporting under the grant. Effect – Lack of notification of the reporting requirement could lead to disallowed costs. We noted that the annual report was subsequently submitted to the grantor. However, our audit disclosed no instances of unallowable costs. Questioned Costs – Not determinable. Recommendation – We recommend the strengthening of controls to ensure annual reporting required under the compliance supplement is performed in a timely manner. Management’s Response – The City will strengthen the controls in place to provide assurance that annual reporting is performed timely in accordance with program guidelines.
Finding 2023-003 Significant deficiency in internal controls over compliance related to reporting. Federal Agency: U.S. Department of Health and Human Services Program Title: Developmental Disabilities Basic Support and Advocacy Grants Assistance Listing Number: 93.630 Awards Number: 2201WAPADD-00 & 03; 2001WAPAPH-00 & 01 Award Period: 10/01/2021 - 9/30/2024 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subpart D section 2 CFR 200.328 (as codified by the Department of Health and Human Services [DHHS] in 45 CFR 75) requires accurate financial reporting to be submitted under the terms of the Federal award. Condition/Context For the year ended September 30, 2023, DRW submitted their required semi-annual SF-425 reporting for the reporting period ending September 30, 2023. Though the reporting was submitted timely, it contained inaccurate information related to the balance of their unused Program Income, excluding their unused balance of approximately $142,000. Effect/Potential Effect DRW did not comply with the accuracy reporting requirement as specific in 2 CFR 200.328 Questioned Costs Not applicable Cause DRW’s internal controls were not designed to ensure accurate reporting Repeat Finding Not applicable Recommendation We recommend that DRW implement internal controls to ensure required reporting includes accurate information. Views of Responsible Officials Management agrees with the finding and has provided the corrective action plan following the Single Audit Report.
Finding 2023-003 Significant deficiency in internal controls over compliance related to reporting. Federal Agency: U.S. Department of Health and Human Services Program Title: Developmental Disabilities Basic Support and Advocacy Grants Assistance Listing Number: 93.630 Awards Number: 2201WAPADD-00 & 03; 2001WAPAPH-00 & 01 Award Period: 10/01/2021 - 9/30/2024 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subpart D section 2 CFR 200.328 (as codified by the Department of Health and Human Services [DHHS] in 45 CFR 75) requires accurate financial reporting to be submitted under the terms of the Federal award. Condition/Context For the year ended September 30, 2023, DRW submitted their required semi-annual SF-425 reporting for the reporting period ending September 30, 2023. Though the reporting was submitted timely, it contained inaccurate information related to the balance of their unused Program Income, excluding their unused balance of approximately $142,000. Effect/Potential Effect DRW did not comply with the accuracy reporting requirement as specific in 2 CFR 200.328 Questioned Costs Not applicable Cause DRW’s internal controls were not designed to ensure accurate reporting Repeat Finding Not applicable Recommendation We recommend that DRW implement internal controls to ensure required reporting includes accurate information. Views of Responsible Officials Management agrees with the finding and has provided the corrective action plan following the Single Audit Report.
Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Assistance Listing Number: 21.027 Compliance Requirement: Reporting Federal Agency: Department of Treasury Criteria or Specific Requirement: In accordance with the Authoritative Requirement 2 CFR 200.328, 31 CFR section 35.4(c) Reporting and request for other information, and the Consolidated Appropriations Act, (CAA), grantees using SLFRF funds for the eligible uses provided in the 2023 CAA will be required to report on their uses of funds in their Project and Expenditure reports. Condition: Required submission of the Project and Expenditure report during fiscal year 2023 was not submitted prior to the reporting deadline. Questioned Costs: None Context: The City’s Project and Expenditure report was selected for testing and it was noted the City did not submit the required report prior to the reporting deadline. Effect: The City did not submit the required Project and Expenditure report by the reporting deadline as required by the Uniform Guidance. Cause: The City did not have adequate internal controls over reporting requirements to ensure that the required report was submitted prior to the reporting deadline. Identification as a Repeat Finding: N/A Recommendation: Management should implement policies and procedures to ensure required reports are completed and filed by their respective due date in accordance with the grant agreement and the Uniform Guidance. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.
Criteria or Specific Requirement 2 CFR 200.328 and 31 CFR section 35.4(c) requires submission of quarterly and annual project and expenditure reports which are due to the Department of Treasury 30 days after the end of each quarter and April 30th, of the year proceeding, respectively. The project and expenditure report contains specific instructions on how to complete the report. Within the project and expenditure report, ‘Expenditure Categories’ is a critical component to be completed by reporting “obligations” and “expenditures” on each project. As defined in the report, “obligation” is an order placed (such as a contract) and similar transactions that require payment; “expenditure” is when the service has been rendered or the good has been delivered to the entity, and payment is due. Condition Upon review and testing of the quarterly reports as submitted to the Department of Treasury, it was noted that amounts reported as expenditures for certain projects included amounts that were obligated but not yet incurred (service was not yet rendered or the good was not yet received) until a subsequent quarter. The expenditures as reported were allowable expenditures, but the timing of the expenditures was reported in the incorrect period. In addition, upon testing the expenditures as reported in the unadjusted schedule of expenditures of federal awards (the “schedule”), it was noted that $415,821 was improperly included as expenditures belonging to the fiscal year ended September 30, 2023. The expenditures identified were prematurely recorded in the general ledger since the equipment was not received until after year-end. The City’s schedule of expenditures of federal awards for the fiscal year ended September 30, 2023 required a correction to remove those amounts from the schedule and to add those amounts to the subsequent fiscal year’s schedule. Cause The Grants Administrator’s lack of understanding of the proper manner in which the obligations and expenditures are required to be reported in the quarterly reports resulted in expenditure amounts being reported in the incorrect quarters. The City’s year-end procedures did not identify certain necessary adjustments in a timely manner in order to remove capital outlay expenditures that were incorrectly recorded during the fiscal year ended September 30, 2023 and were incorrectly included in the unadjusted schedule of expenditures of federal awards. The Grants Administrator utilized the amounts recorded as expenditures in the accounting system to prepare the quarterly reports. Expenditures should be recorded in the City’s general ledger utilizing the date services are rendered and/or goods are received. Proper monthly review of the expenditure accounts should have led to identifying expenditures that were recorded but not yet incurred. Effect or Potential Effect The two conditions listed above resulted in differences between expenditure amounts as correctly adjusted and reported in the schedule of expenditures of federal awards, versus expenditure amounts as reported and submitted to the Department of Treasury in the quarterly reports. Future reports may be incorrectly completed if obligation amounts and expenditure amounts are not following the criteria to properly enter amounts in the quarterly reports. Questioned Costs None. Context During compliance testing of the reporting compliance requirement, it was noted that the total expenditures included in the schedule of expenditures of federal awards for the fiscal year ended September 30, 2023 did not agree to the total expenditures reported in the quarterly expenditure reports as submitted to the Department of Treasury for the same period. During testing of disbursements as included in the schedule of expenditures of federal awards for the major Federal program, and during internal control and compliance testing, it was noted there were two disbursements, amounting to a total of $415,821, recorded within accounts payable as capital outlay expenditures which were improperly recorded in the fiscal year ended September 30, 2023 and improperly included in the schedule of expenditures of federal awards. As evidenced by the invoice date and ship date within the invoices, the equipment was not shipped, and the equipment was not received by the City, until after year-end. The expenditures should be recorded and reported in the fiscal year ended September 30, 2023. Adjustments were made accordingly for proper recording, reporting, and presentation in the financial statements and schedule of expenditures of federal awards. Repeat Finding This is a variation of a prior year finding from 2022. See summary schedule of prior audit findings. Recommendation Management should ensure year-end closing procedures are completed in a timely manner and are sufficient to assure accounts and financial statements are prepared in accordance with GAAP. If properly prepared and recorded, the subledgers for expenditures by federal awards will be generated with accurate expenditure amounts for the fiscal year. Management should assess the risk associated with this condition and identify any additional processes that can be incorporated into their existing controls to improve the deficiency; such as, minimizing the likelihood of year-end material audit adjustments through review of transactions and balances for general propriety and accuracy within one month after year-end. Follow-up and inquiries can be made timely for any transactions for which proper recording is unclear to management, if any. The Grants Administrator should maintain an up-to-date listing of expenditures by award (for all federal, state, and local awards) and should communicate with the Finance Department on a monthly basis to review the listing and determine the proper period in which the expenditures should be recorded and presented. The Grants Administrator and Finance Department should prepare a reconciliation of the expenditures as reported in the schedule of expenditures of federal awards for the major Federal program for the fiscal year ended September 30, 2023, as well as expenditures incurred from October 1, 2023 through today, and compare to the expenditures as reported in all quarterly reports through September 30, 2023 and September 30, 2024. An analysis should be completed to determine the differences between the expenditures incurred by quarter versus expenditures as reported by quarter, and to determine the differences in total between expenditures incurred and expenditures reported in the quarterly and annual project and expenditure reports. The Grants Administrator should then review the Department of Treasury’s Project and Expenditure Report User Guide of State and Local Fiscal Recovery Funds, and/or contact the grantor, to determine if reports as previously submitted should be corrected for the timing difference, or to determine what the correct course of action should be.
Finding 2023-005 – REPORTING Type: Material Weakness in Internal Control/Noncompliance. Program: ALN 93.493 Congressional Directives Criteria: Pursuant to 2 CFR 200.328(c), “The recipient or subrecipient must submit financial reports as required by the Federal award.” According to the closeout requirements of the Federal award, recipients must, “Reconcile financial expenditures to the reported total disbursement and charges in PMS.” Condition: The CMHSP did not reconcile financial expenditures shown in the Federal Financial Report to the total disbursement and charges in PMS. Cause: This condition was caused by an insufficient internal control process for review and approval of grant reports. Effect: Federal share of expenditures listed on the Federal Financial Report were overstated by $361,981. Questioned Cost: None. Context: Amounts received as Federal reimbursement, as detailed in PMS, were supported by the books and records of the CMHSP. However, the final report of expenditures was overstated by $361,981. Recommendation: We recommend that the CMHSP review their internal controls and make necessary changes to ensure that reports adhere to the grant requirements. Management’s Resp: We are in agreement with this finding.
Federal Agency: U. S. Department of Treasury AL No.: 21.027 Program Title: Coronavirus State and Local Fiscal Recovery Funds Area: Reporting Repeat Finding from Prior Audit? No Questioned Cost: $0.00 Criteria: Pursuant to 2 CFR 200.328, recipients of federal grants must submit performance reports that document project progress. These reports should compare actual accomplishments to established goals, explain any delays, and outline corrective actions. For construction projects, additional reporting is required, including project schedules, completion percentages, quality control documentation, and related materials. Additionally, 31 CFR Section 35.4(c) mandates that recipients of federal funds submit periodic reports as required by the awarding agency. Recipients must maintain accurate records supporting financial and performance reports and provide additional information upon request to ensure compliance with federal requirements. As specified in the grant award, recipients must submit quarterly progress reports by the end of the month following each quarter. Condition: For all four quarters, CUC prepared the quarterly reports; however, no assurance was provided as to whether the reports were submitted on time. Cause: The inability to confirm the timely submission of the reports stems from a lack of internal processes or tracking mechanisms to ensure that reports are submitted by the required deadlines. There was no systematic follow-up or verification to ensure compliance with reporting deadlines. Effect: The failure to ensure the timely submission of quarterly reports impacts the federal agency’s ability to effectively monitor and assess the project’s progress. It also creates a risk of noncompliance with federal guidelines, which could lead to delays in funding, increased scrutiny from the awarding agency, and potential administrative penalties. Recommendation: CUC should implement the following corrective actions: 1. Establish and enforce internal controls to ensure the timely preparation and submission of monthly progress reports. 2. Assign responsibility to a designated compliance officer to monitor and verify compliance with reporting requirements. 3. Develop a tracking system to document the submission and review of reports. 4. Provide training to project managers and relevant personnel on reporting obligations under 2 CFR 200.328 and 31 CFR35.4(c). 5. Implement corrective action steps for future noncompliance, including escalation procedures for late or missing reports. Views of the Officials: CUC’s response is documented in the corrective action plan.
Criteria Per 2 CFR §200.328 and §200.302 of the Uniform Guidance, recipients of federal awards must submit performance and financial reports in a timely manner, ensure reports are accurate and reconcilable to financial records, and maintain documentation of internal controls including review procedures. Condition The Organization was unable to provide adequate documentary evidence that it complied with the reporting requirements of the Uniform Guidance. We noted that some reports were not submitted before the stated deadline. In addition, some adjustments were required to reconcile the amounts reported to the federal awarding agencies with the Organization’s accounting records. Cause The Organization’s system of internal control, including control activities, was inadequate to ensure timely submission of required reports or facilitate a reconciliation of reported amounts to the Organization’s accounting records. Additionally, the Organization was unable to provide documentary evidence that reports were reviewed by the appropriate personnel prior to their submission. Effect The lack of supervisory review of the required reports increases the risk of material noncompliance with the reporting requirements set forth in the Uniform Guidance. Furthermore, certain information reported to federal awarding agencies for the fiscal year under audit may be inaccurate or inconsistent with the Organization’s underlying accounting records. Questioned Costs None Context We performed procedures to test the Organization’s reporting practices related to federal awards. We selected a sample of required financial and performance reports submitted to federal awarding agencies for testing. The objective was to verify whether reports were submitted timely, accurately reflected accounting data, and included evidence of management review. During the testing, we were unable to obtain sufficient and appropriate documentary evidence to corroborate the Organization’s compliance with reporting requirements. Recommendation We recommend that management establishes and implements policies that provide for documentary evidence of review of reports required by federal awards by appropriate individuals to ensure the timely submission of required reports. In addition, we recommend that the Organization establishes controls to reconcile the data reported to federal awarding agencies to the Organization’s underlying accounting records. Views of Responsible Officials See the accompanying Corrective Action Plan.
2023-004 – Department of the Interior Federal Program Name: Natural Resource Stewardship - Pass-Through Agency: N/A Assistance Listing Number: 15.944 Federal Award Identification Year: 2023 Award Period: 10/01/2022 – 09/30/2023 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria: 2 CFR 200.328 - 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. 2 CFR 200.329(c)(1) -Requirements state that the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or passthrough entity to best inform improvements in program outcomes and productivity. Condition: For the reports submitted to the National Park Service, there was not documented review and approval of the submission by management. Context: Internal controls need to be formally documented as well as have support and authorization. With no authorization or proof that the internal control was completed, we cannot rely on the controls. Effect: Not having internal controls formalized and documented can lead to higher risk of noncompliance and misreporting. Cause: Internal controls are not formalized or documented. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that CIES modifies its internal control policies for general review and approval of the reporting requirements set forth by the criteria listed above. Management’s Views: See separate corrective action plan.
FEDERAL PROGRAM ALL FEDERAL PROGRAMS ON THE SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS AWARD NUMBERS ALL AWARDS COMPLIANCE REQUIREMENT ACTIVITIES ALLOWED OR UNALLOWED TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA Uniform Guidance at 2 CFR 200 §200.302, Financial Management, establishes that: “(a) Each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State's funds. All recipient and subrecipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. (See § 200.450). (b) The recipient's and subrecipient's financial management system must provide for the following (see §§ 200.334, 200.335, 200.336, and 200.337): (1) Identification of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number, year the Federal award was issued, and name of the Federal agency or pass-through entity. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. When a Federal agency or pass-through entity requires reporting on an accrual basis from a recipient or subrecipient that maintains its records other than on an accrual basis, the recipient or subrecipient must not be required to establish an accrual accounting system. This recipient or subrecipient may develop accrual data for its reports based on an analysis of the documentation on hand. (3) Maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. … (6) Written procedures to implement the requirements of § 200.305. (7) Written procedures for determining the allowability of costs in accordance with subpart E and the terms and conditions of the Federal award.” STATEMENT OF CONDITION As part of our understanding of internal controls and compliance testing regarding activities allowed or unallowed, we obtained a procedures manual. We found the following deficiencies: • The Center provided written internal control procedures over federal funds management. We observed that the policy didn’t include any detail of procedures, just a general requirement. In addition, the policy does not identify the personnel responsible for the processes to establish segregation of duties. • We selected a sample of 10 (number of disbursements selected) federal funds disbursed and noted that invoices are not marked as they are paid. • From the sample of federal funds disbursed, no evidence was found of approval or verification of allowability of the disbursement, proper segregation of duties, or accountability. • The Center lacks an adequate process to provide regular training to staff on Generally Accepted Government Auditing Standards, general documentation, acquisitions levels, formal agreements with vendors, vendor selections guidelines and best practices, required documentation regarding grant requirements and other internal best practices. QUESTIONED COSTS No questioned costs identified. PERSPECTIVE INFORMATION This is a systematic deficiency. After conducting personnel interviews, we were able to identify procedures for validating the payments. The person told us that after a need to purchase goods or services is identified by the centers, the entity Administrator requests authorization from the President. The President validates with the external accounting firm that the expense category is included in the approved budget and that funds are available before approving the payment. Procedures and internal controls manuals should provide for and ensure the segregation of duties. STATEMENT OF CAUSE The Center didn't have adequate internal controls in place, or documentation that presented adequate segregation of duties and compliance with applicable laws and regulations. In addition, no internal controls were documented that supported proper accountability of funds. POSSIBLE ASSERTED EFFECT The Center could incur in unallowable costs or activities and not be able to prevent or detect a transaction that doesn't comply with the Federal regulation. IDENTIFICATION OF REPEAT FINDING No reported as prior audit finding. RECOMMENDATIONS We recommend that management establish an adequate internal controls process that identifies documentation, personnel responsible and authorizations. In addition, we recommend management to update established written procedures and internal controls manuals to provide and document the segregation of duties related to the activities allowed or unallowed compliance requirement.
Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year - 38080710K, 2022 Pass-through Entity - Illinois Department of Public Health (IDPH) Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in Standards for Internal Control in the Federal Government, issued by the Comptroller General of the United States, or the Internal Control-Integrated Framework, issued by the Committee of Sponsoring Organizations (COSO). Per 2 CFR 200.403, except where otherwise authorized by statute, in order to be allowable under Federal awards, costs must be determined in accordance with generally accepted accounting principles (GAAP), incurred during the approved budget period, and adequately documented. Per 2 CFR 200.510, the auditee must prepare a schedule of federal expenditures (SEFA) for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with § 200.502. Per 2 CFR 200.328, the funding agency establishes the financial reporting basis of accounting. Based on the reimbursement certificate template required by the passthrough funding agency, the recipient should report expenditures from expense activity, as well as cash or in-kind matching contributions where applicable. Condition - Management lacked adequate controls at the transaction level to ensure compliance with activities allowed or unallowed, allowable cost principles, and period of performance, which resulted in the improper inclusion of duplicate costs and costs from a prior fiscal period. Further, a lack of effective controls over financial reporting and over preparation of the SEFA resulted in management reporting activity on a cash basis, inconsistent with the basis of reporting established in Note 1 and with requirements established by the passthrough funding agency. Questioned Costs - $109,149 If Questioned Costs Are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could Not Be Reported - N/A Identification of How Questioned Costs Were Computed - Questioned costs totaling $49,754 represent a duplicate invoice found as the result of compliance testing. An additional $59,395 of costs were identified during compliance testing from invoices for goods or services received during fiscal year 2022. Context - During a walkthrough of management's processes and controls, we noted management did not have controls in place at the invoice level for 2 of the 3 vendors charged to the program during the fiscal period under audit to ensure compliance with activities allowed or unallowed, allowable cost principles, or period of performance. As the result of compliance testing, we identified 1 invoice in the amount of $49,754 out of 60 samples that was a duplicate transaction of another sample. As the result of compliance testing, we identified 7 out of 60 transactions totaling $59,395 incurred during the fiscal year ended September 30, 2022. Through discussions with management and in an effort to reconcile the SEFA to underlying general ledger expenditure activity incurred during the fiscal period under audit, we noted that the amount on the SEFA reflected cash reimbursed by IDPH and not expenditures incurred during the fiscal period. In addition, for 2 of the 4 quarterly financial reports selected for testing, we noted that amounts requested for reimbursement for those periods were overstated by approximately $217,000 in aggregate, in relation to the underlying expenditure activity incurred at the time of the submission of the financial report to and request for reimbursement from IDPH. Cause and Effect - A lack of effective controls over the preparation of the SEFA could result in material inaccuracies to the SEFA. A lack of effective controls at the transaction level resulted in noncompliance with accounting principles, duplicate charges to the program, and questioned costs. A lack of effective controls over financial reporting resulted in noncompliance with reporting requirements and an inaccurate reflection of activity incurred during the period reported. Recommendation - We recommend management implement effective controls at the transaction level to ensure costs are allowable under the terms and conditions of the grant agreement have not been duplicated within the population of costs charged to the program and are in compliance with cost principles outlined within the Uniform Guidance. In addition, we recommend that management review the Uniform Guidance and grant agreements carefully to understand the required basis of accounting and to implement an effective set of controls to ensure compliance with these requirements. Views of Responsible Officials and Corrective Action Plan - Management has implemented a new review and oversight process related to the process for the grant submissions in question.
SCHEDULE OF FINDINGS AND QUESTIONED COSTS Financial Statement Findings and Questioned Costs September 30, 2023 Comment #2023-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND SUPPORTIVE SERVICES FOR VETERAN FAMILIES PROGRAM FAL # 93.600 AND 64.003 Condition: As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Authority. The preparation of these financial statements is in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards states in summary, that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The close-out process is designed to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity and experience of the current staff does not allow for adequate analysis of grants and contracts, proper allocations of shared costs and support services provided, grantor receivables, accounts payable, deferred revenue, and the reconciliation of bank accounts accurately and in a timely manner. This resulted in adjustments necessary to properly present the financial statements and disclosures of the Authority as of September 30, 2023. We also noted significant weaknesses in internal controls over personnel payroll and the processing, maintaining and reconciling payroll activity to the general ledger and external regulatory reporting (IRS Form 941's, IRS Form 990 filings, state filings, etc.) Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually). This condition also makes it difficult to prepare accurate external reports required by the various funding sources in a timely manner (i.e. SF-425). The SEFA may exclude pertinent information required by the Uniform Guidance. The systemic cause appears to be the untimely resignation of key personnel, a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of internal accounting controls and monitoring. Context: Review of internal control structure of the Authority’s in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP and GAS. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] (Continued) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§200.327 Financial reporting and 200.328 Monitoring and reporting program performance [2 CFR §200.302(b)(2)]. When applicable to a single audit, the auditor must report as audit findings, significant deficiencies and material weaknesses in internal control over major programs (2 CFR §200.516(a)). In addition, Government Auditing Standards require auditors to report as findings significant deficiencies and material weaknesses in internal control over financial reporting identified during the audit. Effect: The risk exists that financial statements, the SEFA and other accounts and disclosures (including cash, fixed assets, grant-related receivables, deferred revenue, allocations, and cash) may not be recorded properly during the reporting period (interim and annually) and that errors may not be prevented, or detected and corrected, on a timely basis. This condition may also make it difficult for the Authority to prepare accurate and timely external reports required by various regulatory agencies and funding sources (for example, the SF-425, where applicable) and may increase the risk of noncompliance with grant and contract requirements. Cause: The cause appears to be, which may include one or more of the following: untimely resignation or turnover of key personnel; limited availability of personnel with sufficient training and experience in nonprofit and grant accounting and related compliance reporting; changes in systems and/or processes that were not accompanied by commensurate controls; and policies and procedures not being followed consistently throughout the year. Recommendation: We recommend that the Authority strengthen internal controls over the month-end and year-end financial reporting close process and grant/contract closeout activities. At a minimum, the Authority should: 1. Assign qualified personnel (internal staff and/or qualified third-party support under appropriate management oversight) to perform and document key monthly close procedures, including timely bank reconciliations, review of receivables and deferred revenue, review of grant activity, and review/approval of journal entries. 2. Implement and document supervisory review controls over the preparation of financial statements, related disclosures, and the SEFA, including review of significant estimates, allocations, and reconciliations. 3. Establish a compliance calendar and documented procedures to support timely, accurate external regulatory reporting, including IRS Forms 941, IRS Form 990, Form 5500, applicable state filings, and grantor reports such as the SF-425 and other State department filings, where applicable. 4. Provide targeted training and/or hire/retain personnel with appropriate nonprofit and grant accounting experience, including Uniform Guidance reporting requirements, commensurate with the Authority’s size and complexity. (Continued) 5. Update and consistently follow written accounting policies and procedures, including documented reviews and retention of support for key controls. Views of Responsible Officials and Planned Corrective Actions: We concur with this finding - Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Authority’s financial funding sources, the Authority will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. All enhancements will be implemented by September 30, 2026.
Condition The required Annual Project and Expenditure (P & E) Report was submitted late. The report required for the year ended March 31, 2023, was due on April 30, 2023. Criteria 2 CFR 200.328 and 31 CFR section 35.4(c) required financial and performance reporting information. The 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. Context We request the report submitted during the fiscal year to be audited and observed the report was submitted after the due date. Cause The Municipality failed in submission of the required report on time due to lack of knowledge of requisites and instructions about the completion of the report. Effect The Municipality cannot comply with federal regulations; the evaluation of the federal funds use cannot be observed and monitored by the Agency. The situation could affect the program outcomes. Questioned Costs Not determined Recommendation We recommend the Municipality maintain the schedule of the due date of required reports.
Condition The required Annual Project and Expenditure (P & E) Report was submitted late. The report required for the year ended March 31, 2023, was due on April 30, 2023. Criteria 2 CFR 200.328 and 31 CFR section 35.4(c) required financial and performance reporting information. The 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. Context We request the report submitted during the fiscal year to be audited and observed the report was submitted after the due date. Cause The Municipality failed in submission of the required report on time due to lack of knowledge of requisites and instructions about the completion of the report. Effect The Municipality cannot comply with federal regulations; the evaluation of the federal funds use cannot be observed and monitored by the Agency. The situation could affect the program outcomes. Questioned Costs Not determined Recommendation We recommend the Municipality maintain the schedule of the due date of required reports.
2023-003 Department of Justice and State of South Dakota Department of Public Safety FFAL #16.575, 2022-COMBO-00022 Crime Victim Assistance Reporting Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award. 2 CFR 200.327 and 2 CFR 200.328 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with the program requirements. Condition: The Victims’ Service final financial report was not completed and submitted until requested by the auditors. Cause: There was a lapse in the Organization’s internal control process ensuring reporting requirements were fulfilled timely. Effect: Lack of compliance with designed internal controls over reporting could result in the Organization reporting incorrect or incomplete information. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 reports out of 10 reports. Repeat Finding from Prior Year(s): No Recommendation: We recommend management review internal control procedures over reporting to ensure reporting requirements are completed and submitted timely.
Finding: 2023-002 Program Affected: COVID-19 Higher Education Emergency Relief Fund (HEERF) (AL Number 84.425E) Finding Type: Significant deficiency on internal control Criteria: The HEERF I, II, and III funding came with various requirements instituted by the CARES Act, CRRSAA, and ARP and then further defined by the US Department of Education (ED). The ED exercised its reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329 to define three reporting requirements for the HEERF program funds, which include 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. These reporting requirements stipulate specific guidelines regarding when, how, and what information is to be reported on quarterly and the annual reports. Condition: Per review of the University’s annual report, we noted three instances where the amounts and information reported did not agree to the internal records. Issues noted included incorrect amounts and information posted for the Emergency Financial Aid grants, monitoring and suppressing coronavirus, and total of institutional annual expenditures. Cause: Reporting requirements posted by the Department of Education for HEERF program funds have continuously changed with the intent to be made clearer with each subsequent revision. However, it is difficult to draw conclusions on some of the reporting guidance. There were not adequate controls nor review processes in place to monitor the reporting requirements issued by the Department of Education to ensure the annual report was posted accurately. Effect: The effect or possible effect is that the University may be determined ineligible to receive future HEERF program funding. Additionally, the program does not have accurate information regarding how HEERF program funds were expended by the University. Questioned Costs: None Recommendation: Controls should be established to allow for a second detailed review of all reporting of HEERF program funds by an official extensively familiar with the reporting requirements published by the Department of Education and other regulators. Auditee's Response: The reports will be monitored more closely going forward. See attached corrective action plan.
Department of Education COVID-19 Higher Education Emergency Relief Fund (HEERF) – Assistance Listing #84.425E, #84.425F #2023-003 – Major Federal Award Finding – Reporting Significant Deficiency in Internal Controls over Compliance This is a repeat of prior year finding #2022-003. Conditions: We noted during testing of two quarterly reports and one annual report required under the HEERF program that the two quarterly reports selected for testing were not filed timely. There were also no review procedures in place surrounding these quarterly reports. In addition, some inaccuracies were noted within the annual reporting. Criteria: Federal regulations 2 CFR Section 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The quarterly reports for institutional and student aid are required to be updated and posted to the website within 10 days of the end of the quarter. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. Cause/Context: The University did not meet the reporting deadline requirements set forth by the Department of Education for the HEERF program. Only one individual was involved in the reporting process for the quarterly reports. There is a higher likelihood of errors going undetected in the absence of monitoring and review. Inaccuracies were noted in the amounts reported in the 2022 calendar annual report for HEERF student disbursements and institutional expenditures. Recommendation: Management should review the University’s practices related to reporting under the HEERF program to ensure that reports are submitted timely and that more than one individual is involved in the reporting process. Management should also submit a revision of the HEERF calendar 2022 annual report once the reporting portal is reopened by the Department of Education. Views of Responsible Officials and Planned Corrective Actions: The University agrees with the recommendations put forth by the auditors. The University will submit a revised report for the 2022 calendar year and will put a procedure in place to ensure that all reports are reviewed prior to submission. See also attached Corrective Action Plan.