Criteria: 2 C.F.R. § 200.328 states, in part, this information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. Condition: The Mental Health and Recovery Board of Portage County failed to submit the final expenditures report to the Ohio Department of Mental Health and Addiction Services for both awards under the State Opioid Response Grant Program by the November 15, 2024 deadline. Context: During our review of the GFMS reporting system, the reports were subsequently filed on February 21, 2025. However, the County was unable to provide a copy of the report submitted in the system. This is the result of the County not having effective internal controls over reporting requirements. Cause: The County did not have effective internal controls to help ensure that all reporting requirements were met as required by the grant agreement. The lack of internal controls could result in the County failing to track grants appropriately, as well as, submitting late and/or inaccurate reports leading to further noncompliance. Effect: Noncompliance with grant requirements could have an adverse effect on future grant awards by the awarding agency. Recommendation: We recommend the County improve controls over the reporting requirements associated with this program. This includes obtaining a better understanding of the reporting processes.
Finding #2024-003 Lack of Reporting – Rural eConnectivity Pilot Program (ALN 10.752) Federal Agency: U.S. Department of Agriculture Assistance Listing Number (ALN): 10.752 – Rural eConnectivity Pilot Program (Reconnect) Award Year: 2024 Compliance Requirement: Reporting Criteria: In accordance with 2 CFR §200.328, non-federal entities must submit performance and financial reports as required by the terms and conditions of the federal award. These reports must be accurate, complete, and submitted timely to allow the awarding agency to report the project’s progress and financial status. Condition: The Town did not submit required performance reports for the Rural eConnectivity Pilot Program during the 2024 audit. The Town was unaware of the specific reporting requirements required by the USDA and did not have effective communication with the awarding agency to clarify these expectations. Cause: The noncompliance occurred due to a lack of awareness of the reporting requirements and inadequate communication between the Town and the USDA. The Town did not have adequate internal procedures in place to ensure compliance with federal grant reporting requirements. Effect: Failure to submit required reports limits the awarding agency’s ability to monitor the progress and financial integrity of the federal award. Continued noncompliance could result in the withholding of future federal funds or other enforcement actions. Questioned Costs: None. Recommendation: We recommend that the Town develop and implement written procedures to track federal reporting requirements and deadlines. The Town should ensure that all required reports are submitted accurately and on time. Additionally, the Town should establish regular communication with awarding agencies to clarify expectations and maintain compliance throughout the life of the grant. Views of Responsible Officials: Town of Sandwich, New Hampshire’s management concurs with this audit finding.
Criteria or Specific Requirement: The quarterly reporting requirements were stated in the "2 CFR 200.328 and 31 CFR section 35.1(c) Reporting and requests for other information" section of the Federal Register dated January 27, 2022. The US Department of Treasury requries that quarterly reports be submitted to the department if a county has a populaton below 250,000 residents and are allocated more than $10 million in SLFRF funding. The quarterly reports must be completed and submitted within the next month after the quarterly period ended. Condition: The County was not able to provide the SLFRF quarterly report to verify that the report was submitted and completed within a timely manner. Context: The County has been unable to access the SLFRF website due to the County receiving error messages that they have "insuficient access rights on cross-reference id". Questioned Costs: $0 Effect: The County was not in compliance with SLFRF reporting requirements. Cause: The County has received error messages that says they have "insufficent access rights on cross-reference id" and they cannot log-in to the SLFRF portal. Repeat: Yes, years as repeat finding - One. Auditor's Recommendation: We recommend that the County seek out assistance from the US Department of Treasury about correcting their access to the SLFRF quarterly reports. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. The County will seek out assistance so that they can obtain access to the SLFRF quarterly reports.
2024-001 – Program Reporting Requirements – Internal Control Over Compliance – Significant Deficiency (Not a Repeat Finding) Federal Programs Information: Funding Agency: Department of Health and Human Services Title: Head Start and Early Head Start (Head Start Cluster) Assistance Listing Number: 93.600 Award number: 90CI010110 Pass-through entity: Sac and Fox Nation Type of Finding: Significant Deficiency in internal control over compliance (reporting) Criteria: Per 2 CFR Part 200.328 (c), the recipient or subrecipient must submit financial reports as required by the federal award. Timely submission of these reports is essential for compliance with the terms and conditions of the federal award. Condition: During our testing, we noted that CTSA’s controls surrounding the reporting function for this program were not operating effectively to ensure that the reports were filed in a timely manner, as required by the terms of the award. Questioned Costs: None. Context: CTSA did not submit its Real Property Status Report Standard Form (SF)-429-A for the period ended November 30, 2024, due March 30, 2025, until March 31, 2025. Effect: CTSA was not in compliance with the reporting requirements of the noted program. Cause: CTSA did not have an internal control system designed to ensure all reports are submitted by the required due date. Recommendation: We recommend CTSA implement procedures to ensure timely submission of all required reports. Views of Responsible Official: See accompanying Corrective Action Plan.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
Criteria or Specific Requirement: The quarterly reporting requirements were stated in the "2 CFR 200.328 and 31 CFR section 35.1(c) Reporting and requests for other information" section of the Federal Register dated January 27, 2022. The US Department of Treasury requries that quarterly reports be submitted to the department if a county has a populaton below 250,000 residents and are allocated more than $10 million in SLFRF funding. The quarterly reports must be completed and submitted within the next month after the quarterly period ended. Condition: The County was not able to provide the SLFRF quarterly report to verify that the report was submitted and completed within a timely manner. Context: The County has been unable to access the SLFRF website due to the County receiving error messages that they have "insuficient access rights on cross-reference id". Questioned Costs: $0 Effect: The County was not in compliance with SLFRF reporting requirements. Cause: The County has received error messages that says they have "insufficent access rights on cross-reference id" and they cannot log-in to the SLFRF portal. Repeat: Yes, years as repeat finding - One. Auditor's Recommendation: We recommend that the County seek out assistance from the US Department of Treasury about correcting their access to the SLFRF quarterly reports. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. The County will seek out assistance so that they can obtain access to the SLFRF quarterly reports.
2024-001 – Program Reporting Requirements – Internal Control Over Compliance – Significant Deficiency (Not a Repeat Finding) Federal Programs Information: Funding Agency: Department of Health and Human Services Title: Head Start and Early Head Start (Head Start Cluster) Assistance Listing Number: 93.600 Award number: 90CI010110 Pass-through entity: Sac and Fox Nation Type of Finding: Significant Deficiency in internal control over compliance (reporting) Criteria: Per 2 CFR Part 200.328 (c), the recipient or subrecipient must submit financial reports as required by the federal award. Timely submission of these reports is essential for compliance with the terms and conditions of the federal award. Condition: During our testing, we noted that CTSA’s controls surrounding the reporting function for this program were not operating effectively to ensure that the reports were filed in a timely manner, as required by the terms of the award. Questioned Costs: None. Context: CTSA did not submit its Real Property Status Report Standard Form (SF)-429-A for the period ended November 30, 2024, due March 30, 2025, until March 31, 2025. Effect: CTSA was not in compliance with the reporting requirements of the noted program. Cause: CTSA did not have an internal control system designed to ensure all reports are submitted by the required due date. Recommendation: We recommend CTSA implement procedures to ensure timely submission of all required reports. Views of Responsible Official: See accompanying Corrective Action Plan.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding No.: 2024-001 Federal Financial Reports Federal Agency: National Endowment for the Humanities Federal Assistance Listing No.: 45.129 Program: Promotion of the Humanities-Federal State Partnership Requirement: Reporting Type of Finding: Significant Deficiency Federal award no. and year: SO-283113-22 Criteria: 2 CFR 200.328 states that recipients of federal awards must submit financial reports that include OMB-approved government-wide data elements which consist of the Federal Financial Report, as required by the federal award. The Federal Financial Report Instructions provided by the federal awarding agency include instructions for each line item reported in the Federal Financial Report. Condition: The amount of the federal share of expenditures line item reported in one of the Federal Financial Reports submitted in the current year was not reported in accordance with the Federal Financial Report Instructions. Context: We selected all four of the Federal Financial Reports submitted during the current year and noted that for one of the Federal Financial Reports submitted during the year, the amount reported in the federal share of expenditures line item was under reported by approximately $47,000. Cause: The Council has a process in place to support the accurate preparation and review of the Federal Financial Reports, however the Council was not diligent in following this policy. Effect: Failure to properly adhere to the processes in place over the preparation and review of the Federal Financial Reports resulted in an error to one of the submitted Federal Financial Reports. Questioned costs: None Identification of a repeat finding: N/A Recommendations: The Council should diligently follow its existing policy. Views of Responsible Official(s) and Planned Corrective Action: Management concurs with the finding. The report found lacking was reviewed by the Executive Director, and the error was based on a difference between cash and accrual accounting. Management will review federal financial reports with contracted accountants and retrieve source documents before submitting. Management will also review scope of contracted accounting services to ensure it includes review of all NEH reports.
Finding No.: 2024-001 Federal Financial Reports Federal Agency: National Endowment for the Humanities Federal Assistance Listing No.: 45.129 Program: Promotion of the Humanities-Federal State Partnership Requirement: Reporting Type of Finding: Significant Deficiency Federal award no. and year: SO-283113-22 Criteria: 2 CFR 200.328 states that recipients of federal awards must submit financial reports that include OMB-approved government-wide data elements which consist of the Federal Financial Report, as required by the federal award. The Federal Financial Report Instructions provided by the federal awarding agency include instructions for each line item reported in the Federal Financial Report. Condition: The amount of the federal share of expenditures line item reported in one of the Federal Financial Reports submitted in the current year was not reported in accordance with the Federal Financial Report Instructions. Context: We selected all four of the Federal Financial Reports submitted during the current year and noted that for one of the Federal Financial Reports submitted during the year, the amount reported in the federal share of expenditures line item was under reported by approximately $47,000. Cause: The Council has a process in place to support the accurate preparation and review of the Federal Financial Reports, however the Council was not diligent in following this policy. Effect: Failure to properly adhere to the processes in place over the preparation and review of the Federal Financial Reports resulted in an error to one of the submitted Federal Financial Reports. Questioned costs: None Identification of a repeat finding: N/A Recommendations: The Council should diligently follow its existing policy. Views of Responsible Official(s) and Planned Corrective Action: Management concurs with the finding. The report found lacking was reviewed by the Executive Director, and the error was based on a difference between cash and accrual accounting. Management will review federal financial reports with contracted accountants and retrieve source documents before submitting. Management will also review scope of contracted accounting services to ensure it includes review of all NEH reports.
Finding 2024-009 – Reporting (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Higher Education- Institutional Aid, Assistance Listing No. 84.031 Criteria: 2 CFR Part 200.328 & 329 establish reporting requirements for non-federal entities that include timely and accurate reporting. Non-federal entities are also required to establish controls over the reporting process to ensure compliance with reporting requirements. Condition: We selected 2 annual reports submitted during the year to test for controls and compliance. No documentation of review or approval of the reports was available. Cause: The College did not retain documentation of a review and approval of Title III reports submitted. Effect: The College did not have appropriate documentation. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to 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. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-009 – Reporting (Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting that include timely and accurate reporting. Reporting requirements are unique to each awarding agency and criteria is based on the guidelines and regulations set forth by the funding agency. Each program required quarterly reports to be submitted. Condition: We selected nine reports for the three grant programs tested to test for timely and accurate reporting requirements. The following exceptions were noted: • Minority Health: Two Federal Financial Report (FFR) and two Federal Performance Report (FPR) reports tested; the two FFR reports were not submitted by the due date and one FFR report did not agree or reconcile to the accounting records • CDBG: Two quarterly cash reports and the FY23 Consolidated Annual Performance and Evaluation Report (CAPER) tested; the two cash on hand reports did not have supporting documentation for the amounts reported or documentation that amounts were reconciled to the City's accounting system. One cash report was also filed late. • CRF: Two project and expenditure reports tested; one was not submitted and the other was submitted late. Expenditure information for one subrecipient was underreported by $186,364. Cause: Minority Health FFR reports were not submitted until February 2025, well past the due date. In addition, one FFR was not properly supported. CDBG project profit and loss statements did not tie to the numbers on the reports, the reports were submitted based on the IDIS reports from the HUD site and were not reconciled to the general ledger. CRF subaward amounts reported did not reconcile back to the general ledger. Various reports were filed after the due date. Effect: The City did not submit timely and accurate reports in compliance with federal reporting requirements. Questioned Costs: None reported. Recommendation: The City should ensure responsible personnel have a clear understanding of the reporting guidance. The City should implement policies and procedures to monitor due dates and review all reports prepared by the grants department or its designee to ensure accurate and timely reporting. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to 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. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-009 – Reporting (Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting that include timely and accurate reporting. Reporting requirements are unique to each awarding agency and criteria is based on the guidelines and regulations set forth by the funding agency. Each program required quarterly reports to be submitted. Condition: We selected nine reports for the three grant programs tested to test for timely and accurate reporting requirements. The following exceptions were noted: • Minority Health: Two Federal Financial Report (FFR) and two Federal Performance Report (FPR) reports tested; the two FFR reports were not submitted by the due date and one FFR report did not agree or reconcile to the accounting records • CDBG: Two quarterly cash reports and the FY23 Consolidated Annual Performance and Evaluation Report (CAPER) tested; the two cash on hand reports did not have supporting documentation for the amounts reported or documentation that amounts were reconciled to the City's accounting system. One cash report was also filed late. • CRF: Two project and expenditure reports tested; one was not submitted and the other was submitted late. Expenditure information for one subrecipient was underreported by $186,364. Cause: Minority Health FFR reports were not submitted until February 2025, well past the due date. In addition, one FFR was not properly supported. CDBG project profit and loss statements did not tie to the numbers on the reports, the reports were submitted based on the IDIS reports from the HUD site and were not reconciled to the general ledger. CRF subaward amounts reported did not reconcile back to the general ledger. Various reports were filed after the due date. Effect: The City did not submit timely and accurate reports in compliance with federal reporting requirements. Questioned Costs: None reported. Recommendation: The City should ensure responsible personnel have a clear understanding of the reporting guidance. The City should implement policies and procedures to monitor due dates and review all reports prepared by the grants department or its designee to ensure accurate and timely reporting. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to 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. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-009 – Reporting (Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting that include timely and accurate reporting. Reporting requirements are unique to each awarding agency and criteria is based on the guidelines and regulations set forth by the funding agency. Each program required quarterly reports to be submitted. Condition: We selected nine reports for the three grant programs tested to test for timely and accurate reporting requirements. The following exceptions were noted: • Minority Health: Two Federal Financial Report (FFR) and two Federal Performance Report (FPR) reports tested; the two FFR reports were not submitted by the due date and one FFR report did not agree or reconcile to the accounting records • CDBG: Two quarterly cash reports and the FY23 Consolidated Annual Performance and Evaluation Report (CAPER) tested; the two cash on hand reports did not have supporting documentation for the amounts reported or documentation that amounts were reconciled to the City's accounting system. One cash report was also filed late. • CRF: Two project and expenditure reports tested; one was not submitted and the other was submitted late. Expenditure information for one subrecipient was underreported by $186,364. Cause: Minority Health FFR reports were not submitted until February 2025, well past the due date. In addition, one FFR was not properly supported. CDBG project profit and loss statements did not tie to the numbers on the reports, the reports were submitted based on the IDIS reports from the HUD site and were not reconciled to the general ledger. CRF subaward amounts reported did not reconcile back to the general ledger. Various reports were filed after the due date. Effect: The City did not submit timely and accurate reports in compliance with federal reporting requirements. Questioned Costs: None reported. Recommendation: The City should ensure responsible personnel have a clear understanding of the reporting guidance. The City should implement policies and procedures to monitor due dates and review all reports prepared by the grants department or its designee to ensure accurate and timely reporting. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to 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. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-009 – Reporting (Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting that include timely and accurate reporting. Reporting requirements are unique to each awarding agency and criteria is based on the guidelines and regulations set forth by the funding agency. Each program required quarterly reports to be submitted. Condition: We selected nine reports for the three grant programs tested to test for timely and accurate reporting requirements. The following exceptions were noted: • Minority Health: Two Federal Financial Report (FFR) and two Federal Performance Report (FPR) reports tested; the two FFR reports were not submitted by the due date and one FFR report did not agree or reconcile to the accounting records • CDBG: Two quarterly cash reports and the FY23 Consolidated Annual Performance and Evaluation Report (CAPER) tested; the two cash on hand reports did not have supporting documentation for the amounts reported or documentation that amounts were reconciled to the City's accounting system. One cash report was also filed late. • CRF: Two project and expenditure reports tested; one was not submitted and the other was submitted late. Expenditure information for one subrecipient was underreported by $186,364. Cause: Minority Health FFR reports were not submitted until February 2025, well past the due date. In addition, one FFR was not properly supported. CDBG project profit and loss statements did not tie to the numbers on the reports, the reports were submitted based on the IDIS reports from the HUD site and were not reconciled to the general ledger. CRF subaward amounts reported did not reconcile back to the general ledger. Various reports were filed after the due date. Effect: The City did not submit timely and accurate reports in compliance with federal reporting requirements. Questioned Costs: None reported. Recommendation: The City should ensure responsible personnel have a clear understanding of the reporting guidance. The City should implement policies and procedures to monitor due dates and review all reports prepared by the grants department or its designee to ensure accurate and timely reporting. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to 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. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-009 – Reporting (Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting that include timely and accurate reporting. Reporting requirements are unique to each awarding agency and criteria is based on the guidelines and regulations set forth by the funding agency. Each program required quarterly reports to be submitted. Condition: We selected nine reports for the three grant programs tested to test for timely and accurate reporting requirements. The following exceptions were noted: • Minority Health: Two Federal Financial Report (FFR) and two Federal Performance Report (FPR) reports tested; the two FFR reports were not submitted by the due date and one FFR report did not agree or reconcile to the accounting records • CDBG: Two quarterly cash reports and the FY23 Consolidated Annual Performance and Evaluation Report (CAPER) tested; the two cash on hand reports did not have supporting documentation for the amounts reported or documentation that amounts were reconciled to the City's accounting system. One cash report was also filed late. • CRF: Two project and expenditure reports tested; one was not submitted and the other was submitted late. Expenditure information for one subrecipient was underreported by $186,364. Cause: Minority Health FFR reports were not submitted until February 2025, well past the due date. In addition, one FFR was not properly supported. CDBG project profit and loss statements did not tie to the numbers on the reports, the reports were submitted based on the IDIS reports from the HUD site and were not reconciled to the general ledger. CRF subaward amounts reported did not reconcile back to the general ledger. Various reports were filed after the due date. Effect: The City did not submit timely and accurate reports in compliance with federal reporting requirements. Questioned Costs: None reported. Recommendation: The City should ensure responsible personnel have a clear understanding of the reporting guidance. The City should implement policies and procedures to monitor due dates and review all reports prepared by the grants department or its designee to ensure accurate and timely reporting. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to 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. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-009 – Reporting (Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting that include timely and accurate reporting. Reporting requirements are unique to each awarding agency and criteria is based on the guidelines and regulations set forth by the funding agency. Each program required quarterly reports to be submitted. Condition: We selected nine reports for the three grant programs tested to test for timely and accurate reporting requirements. The following exceptions were noted: • Minority Health: Two Federal Financial Report (FFR) and two Federal Performance Report (FPR) reports tested; the two FFR reports were not submitted by the due date and one FFR report did not agree or reconcile to the accounting records • CDBG: Two quarterly cash reports and the FY23 Consolidated Annual Performance and Evaluation Report (CAPER) tested; the two cash on hand reports did not have supporting documentation for the amounts reported or documentation that amounts were reconciled to the City's accounting system. One cash report was also filed late. • CRF: Two project and expenditure reports tested; one was not submitted and the other was submitted late. Expenditure information for one subrecipient was underreported by $186,364. Cause: Minority Health FFR reports were not submitted until February 2025, well past the due date. In addition, one FFR was not properly supported. CDBG project profit and loss statements did not tie to the numbers on the reports, the reports were submitted based on the IDIS reports from the HUD site and were not reconciled to the general ledger. CRF subaward amounts reported did not reconcile back to the general ledger. Various reports were filed after the due date. Effect: The City did not submit timely and accurate reports in compliance with federal reporting requirements. Questioned Costs: None reported. Recommendation: The City should ensure responsible personnel have a clear understanding of the reporting guidance. The City should implement policies and procedures to monitor due dates and review all reports prepared by the grants department or its designee to ensure accurate and timely reporting. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to 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. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-009 – Reporting (Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting that include timely and accurate reporting. Reporting requirements are unique to each awarding agency and criteria is based on the guidelines and regulations set forth by the funding agency. Each program required quarterly reports to be submitted. Condition: We selected nine reports for the three grant programs tested to test for timely and accurate reporting requirements. The following exceptions were noted: • Minority Health: Two Federal Financial Report (FFR) and two Federal Performance Report (FPR) reports tested; the two FFR reports were not submitted by the due date and one FFR report did not agree or reconcile to the accounting records • CDBG: Two quarterly cash reports and the FY23 Consolidated Annual Performance and Evaluation Report (CAPER) tested; the two cash on hand reports did not have supporting documentation for the amounts reported or documentation that amounts were reconciled to the City's accounting system. One cash report was also filed late. • CRF: Two project and expenditure reports tested; one was not submitted and the other was submitted late. Expenditure information for one subrecipient was underreported by $186,364. Cause: Minority Health FFR reports were not submitted until February 2025, well past the due date. In addition, one FFR was not properly supported. CDBG project profit and loss statements did not tie to the numbers on the reports, the reports were submitted based on the IDIS reports from the HUD site and were not reconciled to the general ledger. CRF subaward amounts reported did not reconcile back to the general ledger. Various reports were filed after the due date. Effect: The City did not submit timely and accurate reports in compliance with federal reporting requirements. Questioned Costs: None reported. Recommendation: The City should ensure responsible personnel have a clear understanding of the reporting guidance. The City should implement policies and procedures to monitor due dates and review all reports prepared by the grants department or its designee to ensure accurate and timely reporting. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Reference Number: 2024-003 L. Reporting Compliance Requirement ALN 21.027 Coronavirus State and Local Fiscal Recovery Fund Federal Award Agreement Number: 17460025442 Award Year: 2023-2024 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 two quarterly reports that did not reflect current quarterly activity and no documentation was maintained to support evidence that the report was reviewed. Cause: Documentation of review and accurate submission regarding Q1 and Q2 2024 project and expenditure reports were 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 correctly 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 proper controls and review of all quarterly reports that are submitted through the portal to ensure complete and accurate reports. Views of Responsible Officials: Management agrees with the findings. See corrective action plan beginning on page 230.
Criteria: 2 CFR Section 200.328 requires that the non-federal entity must submit the Federal Financial Report (SF-425) no later than 30 days after the end of a quarterly or semiannually reporting period (or 90 days for annual reporting periods). Condition and context: During testing of the Alliance’s compliance over reporting, we identified the Alliance did not submit the SF-425 forms timely during the year ended September 30, 2024. Cause: The Alliance’s controls and processes were not effectively designed to ensure all reporting requirements are executed timely. Effect: The Alliance was not fully in compliance with the reporting requirements of the Uniform Guidance. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Alliance implement internal controls such as a compliance calendar and designated review procedures to ensure that all federal reporting requirements, including SF-425 filings, are completed accurately and on time. Views of Responsible Official: Management agrees with the finding. See Corrective Action Plan.
Finding 2024-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Program Name: Multiple federal programs Criteria 1. The code of federal regulations – 2 CFR 200.302 Financial management requires 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. (b) The recipient’s and subrecipient’s financial management system must provide for the following: (1) Identification of all Federal awards received and expended and the Federal programs under which they were received. 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. 2. The code of federal regulations – 2 CFR 200.303 Internal controls requires that recipients and subrecipients must: (a) 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 of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award. (c) Evaluate and monitor the recipient’s or subrecipient’s compliance with statutes, regulations, and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified. Condition The following exceptions to the criteria were observed during the performance of the audit procedures: 1. After the completion of internal review and approval process that Amtrak has established for SEFA preparation and review, we have received multiple updated versions of the schedule with changes to FY24 expenditure amounts for three Assistance Listings included on the SEFA. Total expenditures increased by $80.2 million from version 1 to the final version received. 2. The starting point of the SEFA preparation for the current year was not the audited FY23 SEFA submitted to Federal Audit Clearinghouse, as we have identified that Amtrak subsequently made changes to the FY23 internal SEFA document without reconciling the changes to the audited FY23 SEFA, which resulted in the total cumulative expenditures as of 9/30/2023 to be updated and as such impacting the FY24 expenditures for the respective federal programs. One of the adjustments related to the Hudson Yards Concrete Casing project (HYCC-3) which initially incorrectly recorded $25.0 million of prepaid expenditures. 3. As Assistance Listing #20.314 has been obligated as of 9/27/2024, Amtrak has recorded expenditures related to the HYCC-3 project under this program for the established pre-award period, which dated from January 30, 2023 as part of the FY24 expenditures. Previously, a portion of the total expenditures was included within the FY23 SEFA under Assistance Listing #20.315, for the total amount of $15.6 million. This amount was not adjusted out of the cumulative expenditures for Assistance Listing #20.315 until 2025. Consequently, these expenditures were listed both within the FY23 SEFA under Assistance Listing #20.315 and under the FY24 SEFA as Assistance Listing #20.314 expenditures. 4. As part of SEFA preparation as it relates to allocation of operating expenditures across multiple funding sources, certain projects were incorrectly mapped to annual grants funding source, which resulted in approximately $0.3 million of operating expenses to be included within Assistance Listing #20.315 that were also reported under Assistance Listing #97.075. Cause Amtrak’s control procedures in place as it relates to the preparation of the SEFA were not operating in a manner that would timely identify the conditions noted. Additionally, Amtrak’s controls around allocation of federal funding to project codes were not designed in a manner that would timely identify the conditions noted. In reviewing management’s controls around the SEFA preparation, the design of key controls identified by management does not include an overarching review of the SEFA and reconciliation of what’s been reported on the SEFA from individual projects’ standpoint when such projects have multiple assistance listings as funding sources. We also noted that there was not a specific control that ensures timely updates of Work Breakdown Structure (WBS) funding assignments and allocations when there is a change such as a new grant agreement signed. Effect Amtrak’s control procedures in place as it relates to the preparation of the SEFA were not designed in such a manner that would timely identify the conditions noted, which resulted in several versions of the SEFA that were erroneous and inclusion of expenditures that were double counted within the SEFA. This puts Amtrak at greater risk of non-compliance with its grant agreements with respect to questioned costs and an inaccurate SEFA. Questioned Costs None. Context The SEFA, as originally provided, had exceptions as described in the Condition section above noted for matters 1 and 2 in the Criteria section above, indicating that certain internal controls were not functioning as designed and others were not designed effectively. Identification as a Repeat Finding Not a repeat finding. Recommendation We recommend Amtrak to strengthen the SEFA oversight process to ensure appropriate preparation and review of the SEFA to validate its accuracy, including reconciliation with prior year audited SEFA. This should include having one reviewer take overall responsibility for the completeness and accuracy of the final submitted SEFA. This robust review process should include appropriate procedures to confirm accuracy of the SEFA, which may include a protocol where representatives from various groups (both discretionary and non-discretionary federal programs) work collaboratively to review the SEFA and underlying details of expenditures, to ensure all the adjustments have been properly reflected as well as any projects that might have multiple fund sources are identified timely and reviewed for appropriate inclusion within the SEFA. Additionally, Amtrak should establish a process where any modifications of WBS funding assignments and allocations are updated in a timely manner. Views of Responsible Officials Amtrak recognizes the need to improve the preparation and review of the SEFA. The company has documented the steps for preparing and reviewing the SEFA within its process narrative. The company will update the narrative to address the preparation and review issues that led to the multiple versions of the SEFA being provided during the audit. The company will review and update the Grants Management Compliance Narrative and controls to improve timing of updates for modifications of WBS funding assignments. The company is in the process of updating the SEFA preparation documentation for FY2025, which will be used at the end of the year. The review procedures and controls are being enhanced to include a checklist to improve the review.
Finding 2024-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Program Name: Multiple federal programs Criteria 1. The code of federal regulations – 2 CFR 200.302 Financial management requires 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. (b) The recipient’s and subrecipient’s financial management system must provide for the following: (1) Identification of all Federal awards received and expended and the Federal programs under which they were received. 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. 2. The code of federal regulations – 2 CFR 200.303 Internal controls requires that recipients and subrecipients must: (a) 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 of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award. (c) Evaluate and monitor the recipient’s or subrecipient’s compliance with statutes, regulations, and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified. Condition The following exceptions to the criteria were observed during the performance of the audit procedures: 1. After the completion of internal review and approval process that Amtrak has established for SEFA preparation and review, we have received multiple updated versions of the schedule with changes to FY24 expenditure amounts for three Assistance Listings included on the SEFA. Total expenditures increased by $80.2 million from version 1 to the final version received. 2. The starting point of the SEFA preparation for the current year was not the audited FY23 SEFA submitted to Federal Audit Clearinghouse, as we have identified that Amtrak subsequently made changes to the FY23 internal SEFA document without reconciling the changes to the audited FY23 SEFA, which resulted in the total cumulative expenditures as of 9/30/2023 to be updated and as such impacting the FY24 expenditures for the respective federal programs. One of the adjustments related to the Hudson Yards Concrete Casing project (HYCC-3) which initially incorrectly recorded $25.0 million of prepaid expenditures. 3. As Assistance Listing #20.314 has been obligated as of 9/27/2024, Amtrak has recorded expenditures related to the HYCC-3 project under this program for the established pre-award period, which dated from January 30, 2023 as part of the FY24 expenditures. Previously, a portion of the total expenditures was included within the FY23 SEFA under Assistance Listing #20.315, for the total amount of $15.6 million. This amount was not adjusted out of the cumulative expenditures for Assistance Listing #20.315 until 2025. Consequently, these expenditures were listed both within the FY23 SEFA under Assistance Listing #20.315 and under the FY24 SEFA as Assistance Listing #20.314 expenditures. 4. As part of SEFA preparation as it relates to allocation of operating expenditures across multiple funding sources, certain projects were incorrectly mapped to annual grants funding source, which resulted in approximately $0.3 million of operating expenses to be included within Assistance Listing #20.315 that were also reported under Assistance Listing #97.075. Cause Amtrak’s control procedures in place as it relates to the preparation of the SEFA were not operating in a manner that would timely identify the conditions noted. Additionally, Amtrak’s controls around allocation of federal funding to project codes were not designed in a manner that would timely identify the conditions noted. In reviewing management’s controls around the SEFA preparation, the design of key controls identified by management does not include an overarching review of the SEFA and reconciliation of what’s been reported on the SEFA from individual projects’ standpoint when such projects have multiple assistance listings as funding sources. We also noted that there was not a specific control that ensures timely updates of Work Breakdown Structure (WBS) funding assignments and allocations when there is a change such as a new grant agreement signed. Effect Amtrak’s control procedures in place as it relates to the preparation of the SEFA were not designed in such a manner that would timely identify the conditions noted, which resulted in several versions of the SEFA that were erroneous and inclusion of expenditures that were double counted within the SEFA. This puts Amtrak at greater risk of non-compliance with its grant agreements with respect to questioned costs and an inaccurate SEFA. Questioned Costs None. Context The SEFA, as originally provided, had exceptions as described in the Condition section above noted for matters 1 and 2 in the Criteria section above, indicating that certain internal controls were not functioning as designed and others were not designed effectively. Identification as a Repeat Finding Not a repeat finding. Recommendation We recommend Amtrak to strengthen the SEFA oversight process to ensure appropriate preparation and review of the SEFA to validate its accuracy, including reconciliation with prior year audited SEFA. This should include having one reviewer take overall responsibility for the completeness and accuracy of the final submitted SEFA. This robust review process should include appropriate procedures to confirm accuracy of the SEFA, which may include a protocol where representatives from various groups (both discretionary and non-discretionary federal programs) work collaboratively to review the SEFA and underlying details of expenditures, to ensure all the adjustments have been properly reflected as well as any projects that might have multiple fund sources are identified timely and reviewed for appropriate inclusion within the SEFA. Additionally, Amtrak should establish a process where any modifications of WBS funding assignments and allocations are updated in a timely manner. Views of Responsible Officials Amtrak recognizes the need to improve the preparation and review of the SEFA. The company has documented the steps for preparing and reviewing the SEFA within its process narrative. The company will update the narrative to address the preparation and review issues that led to the multiple versions of the SEFA being provided during the audit. The company will review and update the Grants Management Compliance Narrative and controls to improve timing of updates for modifications of WBS funding assignments. The company is in the process of updating the SEFA preparation documentation for FY2025, which will be used at the end of the year. The review procedures and controls are being enhanced to include a checklist to improve the review.
2024-002 - Late Submission of Reports Finding Type. Immaterial Noncompliance; Significant Deficiency over Compliance (Reporting). Program. VA Supportive Services for Veteran Families Program; Department of Veterans Affairs, Assistance Listing Number 64.033; All Award Numbers. Criteria. Per 2 CFR Part 200.328 (c), the recipient or subrecipient must submit financial reports as required by the federal award. Timely submission of these reports is essential for compliance with the terms and conditions of the federal award. Condition. The Agency failed to submit the required report for the federal grant within the stipulated deadlines as outlined in the grant agreement and Uniform Guidance. During reporting testing, it was noted that the Final FFR report was not submitted into the Payment Management Services (PMS) prior to the required due date. Cause. The delay in reporting was due to inadequate internal controls over the grant management process, including insufficient staffing and lack of proper training for personnel responsible for preparing and submitting the reports. Processes in place were not sufficient to prevent the report from being submitted late. Effect. Late submission of reports results in noncompliance with federal regulations, potentially leading to administrative actions such as withholding of future grant funds, increased monitoring, or other penalties as deemed appropriate by the Federal awarding agency. The Agency did not comply with contractual reporting requirements. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend the Agency implement procedures to ensure timely submission of all required reports. View of Responsible Official. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-002 - Late Submission of Reports Finding Type. Immaterial Noncompliance; Significant Deficiency over Compliance (Reporting). Program. VA Supportive Services for Veteran Families Program; Department of Veterans Affairs, Assistance Listing Number 64.033; All Award Numbers. Criteria. Per 2 CFR Part 200.328 (c), the recipient or subrecipient must submit financial reports as required by the federal award. Timely submission of these reports is essential for compliance with the terms and conditions of the federal award. Condition. The Agency failed to submit the required report for the federal grant within the stipulated deadlines as outlined in the grant agreement and Uniform Guidance. During reporting testing, it was noted that the Final FFR report was not submitted into the Payment Management Services (PMS) prior to the required due date. Cause. The delay in reporting was due to inadequate internal controls over the grant management process, including insufficient staffing and lack of proper training for personnel responsible for preparing and submitting the reports. Processes in place were not sufficient to prevent the report from being submitted late. Effect. Late submission of reports results in noncompliance with federal regulations, potentially leading to administrative actions such as withholding of future grant funds, increased monitoring, or other penalties as deemed appropriate by the Federal awarding agency. The Agency did not comply with contractual reporting requirements. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend the Agency implement procedures to ensure timely submission of all required reports. View of Responsible Official. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-002 - Late Submission of Reports Finding Type. Immaterial Noncompliance; Significant Deficiency over Compliance (Reporting). Program. VA Supportive Services for Veteran Families Program; Department of Veterans Affairs, Assistance Listing Number 64.033; All Award Numbers. Criteria. Per 2 CFR Part 200.328 (c), the recipient or subrecipient must submit financial reports as required by the federal award. Timely submission of these reports is essential for compliance with the terms and conditions of the federal award. Condition. The Agency failed to submit the required report for the federal grant within the stipulated deadlines as outlined in the grant agreement and Uniform Guidance. During reporting testing, it was noted that the Final FFR report was not submitted into the Payment Management Services (PMS) prior to the required due date. Cause. The delay in reporting was due to inadequate internal controls over the grant management process, including insufficient staffing and lack of proper training for personnel responsible for preparing and submitting the reports. Processes in place were not sufficient to prevent the report from being submitted late. Effect. Late submission of reports results in noncompliance with federal regulations, potentially leading to administrative actions such as withholding of future grant funds, increased monitoring, or other penalties as deemed appropriate by the Federal awarding agency. The Agency did not comply with contractual reporting requirements. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend the Agency implement procedures to ensure timely submission of all required reports. View of Responsible Official. Management agrees with this finding and has prepared a Corrective Action Plan.
Criteria: Per Title 2 CFR § 200.328, the recipient must submit annual financial reports no later than 90 calendar days after the reporting period, and semi-annual reports no later than 30 days after the reporting period. Condition: The semi-annual SF-425 financial report was not submitted timely. Cause: The semi-annual SF-425 financial report was not submitted within the 30-day timeframe as required by the Head Start Grant Program. Effect or Potential Effect: Late submissions resulted in non-compliance with reporting requirements and could result in loss or reduction of funding for the program. Context: The semi-annual SF-425 financial report was not filed within 30-days of period end as required in the grant agreement. Recommendation: We recommend that the Organization implement procedure to ensure compliance with filing requirements. Views of Management: Management acknowledges the lapse in regularly meeting the grant requirement of submitting financial reports within the specified 30-day period. To address this issue, the Organization has initiated a comprehensive procedural shift.
Criteria or Specific Requirements: 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. Under grant agreements, program 10.761 and 66.446 require both financial and performance reports to be submitted quarterly within 12 days after quarter-end, while ALN program 93.570 requires semiannual financial and performance reports within 30 days after period-end. Condition: During the review of reporting compliance for the major programs, it was determined that the Organization did not file the FFATA report for program 93.570 within the required 30-day period, and did not submit quarterly financial reports for program 10.761 within the required 12-day deadline after quarter-end. 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 financial reports in a timely manner. Effect: Failure to submit the FFATA report by the end of the month following award of a subgrant over $30,000 results in noncompliance with 2 CFR § 170. Additionally, failure to submit quarterly financial reports for program 10.761 within the required deadline constitutes noncompliance with the Federal Financial Reporting requirement under 2 CFR § 200.328. 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 one out of one samples tested for this compliance requirement were not completed. Further, for program 10.761 quarterly financial reports, one out of two samples tested – drawn from a population of 10 – was not submitted within the required 12-day time frame. Noncompliance surrounding reporting was identified for the following awards during the fiscal 2024: Federal Agency Pass-Through Entity ALN Federal Award Name Award Year Department of Health and Human Services Direct 93.570 HHS RCD 9/30/2023 – 9/29/2024 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Technitrain 2023 – 2024 9/1/2023 – 9/30/2026 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Tribal 2023 - 2024 9/1/2023 – 9/30/2026 Repeat Finding: Yes – Repeat of FY 2024 Finding 2023-005. Recommendations: We recommend that management and relevant staff participate in comprehensive training on federal grant compliance—emphasizing FFATA obligations and financial reporting deadlines—to ensure a clear understanding of requirements. Management should then formalize and document procedures for FFATA reporting, including a calendar-driven workflow with designated preparers and approvers, mandatory sign-off checklists, and automated reminders. Finally, the Organization should implement a centralized reporting-tracking system that monitors all federal award deadlines and captures evidence of timely preparation, review, and submission for both financial and performance reports.
Criteria or Specific Requirements: 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. Under grant agreements, program 10.761 and 66.446 require both financial and performance reports to be submitted quarterly within 12 days after quarter-end, while ALN program 93.570 requires semiannual financial and performance reports within 30 days after period-end. Condition: During the review of reporting compliance for the major programs, it was determined that the Organization did not file the FFATA report for program 93.570 within the required 30-day period, and did not submit quarterly financial reports for program 10.761 within the required 12-day deadline after quarter-end. 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 financial reports in a timely manner. Effect: Failure to submit the FFATA report by the end of the month following award of a subgrant over $30,000 results in noncompliance with 2 CFR § 170. Additionally, failure to submit quarterly financial reports for program 10.761 within the required deadline constitutes noncompliance with the Federal Financial Reporting requirement under 2 CFR § 200.328. 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 one out of one samples tested for this compliance requirement were not completed. Further, for program 10.761 quarterly financial reports, one out of two samples tested – drawn from a population of 10 – was not submitted within the required 12-day time frame. Noncompliance surrounding reporting was identified for the following awards during the fiscal 2024: Federal Agency Pass-Through Entity ALN Federal Award Name Award Year Department of Health and Human Services Direct 93.570 HHS RCD 9/30/2023 – 9/29/2024 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Technitrain 2023 – 2024 9/1/2023 – 9/30/2026 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Tribal 2023 - 2024 9/1/2023 – 9/30/2026 Repeat Finding: Yes – Repeat of FY 2024 Finding 2023-005. Recommendations: We recommend that management and relevant staff participate in comprehensive training on federal grant compliance—emphasizing FFATA obligations and financial reporting deadlines—to ensure a clear understanding of requirements. Management should then formalize and document procedures for FFATA reporting, including a calendar-driven workflow with designated preparers and approvers, mandatory sign-off checklists, and automated reminders. Finally, the Organization should implement a centralized reporting-tracking system that monitors all federal award deadlines and captures evidence of timely preparation, review, and submission for both financial and performance reports.
Criteria or Specific Requirements: 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. Under grant agreements, program 10.761 and 66.446 require both financial and performance reports to be submitted quarterly within 12 days after quarter-end, while ALN program 93.570 requires semiannual financial and performance reports within 30 days after period-end. Condition: During the review of reporting compliance for the major programs, it was determined that the Organization did not file the FFATA report for program 93.570 within the required 30-day period, and did not submit quarterly financial reports for program 10.761 within the required 12-day deadline after quarter-end. 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 financial reports in a timely manner. Effect: Failure to submit the FFATA report by the end of the month following award of a subgrant over $30,000 results in noncompliance with 2 CFR § 170. Additionally, failure to submit quarterly financial reports for program 10.761 within the required deadline constitutes noncompliance with the Federal Financial Reporting requirement under 2 CFR § 200.328. 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 one out of one samples tested for this compliance requirement were not completed. Further, for program 10.761 quarterly financial reports, one out of two samples tested – drawn from a population of 10 – was not submitted within the required 12-day time frame. Noncompliance surrounding reporting was identified for the following awards during the fiscal 2024: Federal Agency Pass-Through Entity ALN Federal Award Name Award Year Department of Health and Human Services Direct 93.570 HHS RCD 9/30/2023 – 9/29/2024 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Technitrain 2023 – 2024 9/1/2023 – 9/30/2026 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Tribal 2023 - 2024 9/1/2023 – 9/30/2026 Repeat Finding: Yes – Repeat of FY 2024 Finding 2023-005. Recommendations: We recommend that management and relevant staff participate in comprehensive training on federal grant compliance—emphasizing FFATA obligations and financial reporting deadlines—to ensure a clear understanding of requirements. Management should then formalize and document procedures for FFATA reporting, including a calendar-driven workflow with designated preparers and approvers, mandatory sign-off checklists, and automated reminders. Finally, the Organization should implement a centralized reporting-tracking system that monitors all federal award deadlines and captures evidence of timely preparation, review, and submission for both financial and performance reports.
Finding 2024-005 – REPORTING (repeat finding) Type: Material Weakness in Internal Control/Noncompliance. Program: ALN 93.493 Congressional Directives Grant Name: Access to Behavioral Crisis Services Grantor Number: FG-22-099 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 file the required annual Federal Financial Report as required for this grant. Cause: This condition was caused by an insufficient internal control process for grant reporting. Effect: Reporting requirements required by the grant were not met. Questioned Cost: None. Context: Amounts received as Federal reimbursement, as detailed in PMS, were supported by the CMHSP’s internal records. However, the final report of expenses was never submitted. Recommendation: We recommend that the CMHSP review their internal controls and make necessary changes to ensure that reports are filed in accordance with the grant requirements. Management’s Resp: We are in agreement with this finding.
Condition: In accordance with 2 CFR-200.328 and 2 CFR-200.303, non-federal entities must submit performance and financial reports as required by the awarding agency and must establish and maintain effective internal control over compliance with federal statutes, regulations, and the terms and conditions of the federal award. Context: The City is required to submit monthly progress reports ten calendar days after the end of each month, quarterly progress reports no later than the 10th of quarter end, and a bi-annual Contract and Subcontract Activity form (HUD-2516), to be submitted by April 15 and October 15 each year. Per testing, monthly and quarterly reports were submitted 10 to 27 days after the deadline. ABPA was unable to obtain evidence that form HUD-2516 was submitted by either of the required due dates. Effect: Failure to submit required reports in a timely manner, and the lack of supporting documentation, represents a deficiency in internal control over compliance. This increases the risk of noncompliance with federal reporting requirements, which could result in questioned costs, delayed reimbursements, or jeopardize future funding. Cause: Delays in report submission were primarily due to insufficient internal controls over the reporting process, lack of clear assignment of responsibilities, and inadequate monitoring of reporting deadlines. Questioned costs: None. Recommendation: We recommend that the City strengthen its internal controls over compliance by implementing a centralized reporting calendar or system to monitor federal reporting deadlines. In addition, procedures should be established to ensure that documentation of timely report submission is retained in the grant files. Staff responsible for grant administration should also receive training on federal reporting requirements.
Finding 2024-009 – Reporting (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Higher Education- Institutional Aid, Assistance Listing No. 84.031 Criteria: 2 CFR Part 200.328 & 329 establish reporting requirements for non-federal entities that include timely and accurate reporting. Non-federal entities are also required to establish controls over the reporting process to ensure compliance with reporting requirements. Condition: We selected 2 annual reports submitted during the year to test for controls and compliance. No documentation of review or approval of the reports was available. Cause: The College did not retain documentation of a review and approval of Title III reports submitted. Effect: The College did not have appropriate documentation. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to 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. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-009 – Reporting (Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting that include timely and accurate reporting. Reporting requirements are unique to each awarding agency and criteria is based on the guidelines and regulations set forth by the funding agency. Each program required quarterly reports to be submitted. Condition: We selected nine reports for the three grant programs tested to test for timely and accurate reporting requirements. The following exceptions were noted: • Minority Health: Two Federal Financial Report (FFR) and two Federal Performance Report (FPR) reports tested; the two FFR reports were not submitted by the due date and one FFR report did not agree or reconcile to the accounting records • CDBG: Two quarterly cash reports and the FY23 Consolidated Annual Performance and Evaluation Report (CAPER) tested; the two cash on hand reports did not have supporting documentation for the amounts reported or documentation that amounts were reconciled to the City's accounting system. One cash report was also filed late. • CRF: Two project and expenditure reports tested; one was not submitted and the other was submitted late. Expenditure information for one subrecipient was underreported by $186,364. Cause: Minority Health FFR reports were not submitted until February 2025, well past the due date. In addition, one FFR was not properly supported. CDBG project profit and loss statements did not tie to the numbers on the reports, the reports were submitted based on the IDIS reports from the HUD site and were not reconciled to the general ledger. CRF subaward amounts reported did not reconcile back to the general ledger. Various reports were filed after the due date. Effect: The City did not submit timely and accurate reports in compliance with federal reporting requirements. Questioned Costs: None reported. Recommendation: The City should ensure responsible personnel have a clear understanding of the reporting guidance. The City should implement policies and procedures to monitor due dates and review all reports prepared by the grants department or its designee to ensure accurate and timely reporting. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to 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. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.