Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For one quarterly report, the supporting documentation maintained did not agree to the information included in the report. Additionally, the Annual Report for 2022 was not prepared. Context: For quarterly reporting, we selected a non-statistical sample of two Quarterly Reporting Forms for testing, noting that for one report, discrepancies between the supporting documentation and the information in the report existed in 3 out of 6 lines of data. For annual reporting, management indicated that they did not believe they were required to prepare the Annual Report for 2022 as all program funds were expended prior to December 31, 2022. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, it was necessary to gather information from various sources within the University. However, the turnover of staff resulted in a lack of retention of this information in a manner conducive to easy retrieval, compilation and reconciliation with reported amounts. Effect: The Quarterly Reporting Forms that were completed may contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to submit the Annual Report for 2022. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2022-002. Recommendations: As the HEERF Program has ended for the University, we recommend that if similar programs become available in the future, management should develop well-documented policies and procedures. These should be detailed enough to ensure that essential knowledge and information for report preparation, including information sources, can withstand significant staff turnover. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and the Office of Financial Aid endeavor to follow all applicable reporting regulations and guidance mandated for federally funded grant and contract programs. The HEERF awards were fully expended as of June 30, 2022 for the Student Portion and as of September 30, 2022 for the Institutional Portion. Should similar programs become available in the future, management will develop, in advance of expending funds, documented policies and procedures to administer the program and will maintain documentation demonstrating compliance with program requirements and related institutional policy and procedure.
Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For one quarterly report, the supporting documentation maintained did not agree to the information included in the report. Additionally, the Annual Report for 2022 was not prepared. Context: For quarterly reporting, we selected a non-statistical sample of two Quarterly Reporting Forms for testing, noting that for one report, discrepancies between the supporting documentation and the information in the report existed in 3 out of 6 lines of data. For annual reporting, management indicated that they did not believe they were required to prepare the Annual Report for 2022 as all program funds were expended prior to December 31, 2022. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, it was necessary to gather information from various sources within the University. However, the turnover of staff resulted in a lack of retention of this information in a manner conducive to easy retrieval, compilation and reconciliation with reported amounts. Effect: The Quarterly Reporting Forms that were completed may contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to submit the Annual Report for 2022. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2022-002. Recommendations: As the HEERF Program has ended for the University, we recommend that if similar programs become available in the future, management should develop well-documented policies and procedures. These should be detailed enough to ensure that essential knowledge and information for report preparation, including information sources, can withstand significant staff turnover. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and the Office of Financial Aid endeavor to follow all applicable reporting regulations and guidance mandated for federally funded grant and contract programs. The HEERF awards were fully expended as of June 30, 2022 for the Student Portion and as of September 30, 2022 for the Institutional Portion. Should similar programs become available in the future, management will develop, in advance of expending funds, documented policies and procedures to administer the program and will maintain documentation demonstrating compliance with program requirements and related institutional policy and procedure.
FINDING 2023-005 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and key line items such as "Number of Specific Positions Supported with Esser Funds," "Allocation of ESSER funds," "Expenditures per Activity," and "Full-Time Equivalency Positions." During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. There was no evidence of an oversight or review process in place to prevent, or detect and correct, errors. All six reports were selected for testing. For four of the six annual data reports the report could not be traced to the records, nor could the accuracy and completeness of the reports be verified. The errors identified were as follows: The ESSER I, Year 2 report, which covered the period of October 1, 2020 to June 30, 2021, reported total expenses of $260,064. However, the School Corporation's ledger for the same period had total expenses of $264,832. Of the reported expenditures, $219,703 could not be determined to be properly categorized. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. INDIANA STATE BOARD OF ACCOUNTS 26 WASHINGTON COMMUNITY SCHOOLS, INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The ESSER I, Year 3 report, which covered the period of July 1, 2021 to June 30, 2022, reported total expenses of $86,521. However, the School Corporation's ledger for the same period had total expenses of $78,230. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The ESSER II, Year 1 and Year 2 reports, which covered the periods of July 1, 2020 to June 30, 2021, and July 1, 2021 to June 30, 2022, respectively, Key Line Items were not able to be traced to supporting documentation. The Expenditures by Subgrant Fund, expenditure category, and object code were supported by the School Corporation's records; however, the School Corporation did not provide supporting documentation for the nonfinancial data required to be submitted with the reports. The ESSER III, Year 1 report, which covered the period of July 1, 2020 to June 30, 2021, reported total expenses of $41,340. However, the School Corporation's ledger for the same period had total expenses of $20,670. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The ESSER III, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, reported total expenses of $1,407,299, which agreed to the School Corporation's ledger. However, $644,730 of the reported expenditures could not be determined to be properly categorized. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." INDIANA STATE BOARD OF ACCOUNTS 27 WASHINGTON COMMUNITY SCHOOLS, INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the reports were not supported by the School Corporation's underlying accounting records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure all reports submitted on behalf of the COVID-19 - Education Stabilization Fund program funds are supported by the School Corporation's underlying accounting records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-005 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and key line items such as "Number of Specific Positions Supported with Esser Funds," "Allocation of ESSER funds," "Expenditures per Activity," and "Full-Time Equivalency Positions." During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. There was no evidence of an oversight or review process in place to prevent, or detect and correct, errors. All six reports were selected for testing. For four of the six annual data reports the report could not be traced to the records, nor could the accuracy and completeness of the reports be verified. The errors identified were as follows: The ESSER I, Year 2 report, which covered the period of October 1, 2020 to June 30, 2021, reported total expenses of $260,064. However, the School Corporation's ledger for the same period had total expenses of $264,832. Of the reported expenditures, $219,703 could not be determined to be properly categorized. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. INDIANA STATE BOARD OF ACCOUNTS 26 WASHINGTON COMMUNITY SCHOOLS, INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The ESSER I, Year 3 report, which covered the period of July 1, 2021 to June 30, 2022, reported total expenses of $86,521. However, the School Corporation's ledger for the same period had total expenses of $78,230. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The ESSER II, Year 1 and Year 2 reports, which covered the periods of July 1, 2020 to June 30, 2021, and July 1, 2021 to June 30, 2022, respectively, Key Line Items were not able to be traced to supporting documentation. The Expenditures by Subgrant Fund, expenditure category, and object code were supported by the School Corporation's records; however, the School Corporation did not provide supporting documentation for the nonfinancial data required to be submitted with the reports. The ESSER III, Year 1 report, which covered the period of July 1, 2020 to June 30, 2021, reported total expenses of $41,340. However, the School Corporation's ledger for the same period had total expenses of $20,670. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The ESSER III, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, reported total expenses of $1,407,299, which agreed to the School Corporation's ledger. However, $644,730 of the reported expenditures could not be determined to be properly categorized. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." INDIANA STATE BOARD OF ACCOUNTS 27 WASHINGTON COMMUNITY SCHOOLS, INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the reports were not supported by the School Corporation's underlying accounting records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure all reports submitted on behalf of the COVID-19 - Education Stabilization Fund program funds are supported by the School Corporation's underlying accounting records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-005 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and key line items such as "Number of Specific Positions Supported with Esser Funds," "Allocation of ESSER funds," "Expenditures per Activity," and "Full-Time Equivalency Positions." During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. There was no evidence of an oversight or review process in place to prevent, or detect and correct, errors. All six reports were selected for testing. For four of the six annual data reports the report could not be traced to the records, nor could the accuracy and completeness of the reports be verified. The errors identified were as follows: The ESSER I, Year 2 report, which covered the period of October 1, 2020 to June 30, 2021, reported total expenses of $260,064. However, the School Corporation's ledger for the same period had total expenses of $264,832. Of the reported expenditures, $219,703 could not be determined to be properly categorized. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. INDIANA STATE BOARD OF ACCOUNTS 26 WASHINGTON COMMUNITY SCHOOLS, INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The ESSER I, Year 3 report, which covered the period of July 1, 2021 to June 30, 2022, reported total expenses of $86,521. However, the School Corporation's ledger for the same period had total expenses of $78,230. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The ESSER II, Year 1 and Year 2 reports, which covered the periods of July 1, 2020 to June 30, 2021, and July 1, 2021 to June 30, 2022, respectively, Key Line Items were not able to be traced to supporting documentation. The Expenditures by Subgrant Fund, expenditure category, and object code were supported by the School Corporation's records; however, the School Corporation did not provide supporting documentation for the nonfinancial data required to be submitted with the reports. The ESSER III, Year 1 report, which covered the period of July 1, 2020 to June 30, 2021, reported total expenses of $41,340. However, the School Corporation's ledger for the same period had total expenses of $20,670. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The ESSER III, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, reported total expenses of $1,407,299, which agreed to the School Corporation's ledger. However, $644,730 of the reported expenditures could not be determined to be properly categorized. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." INDIANA STATE BOARD OF ACCOUNTS 27 WASHINGTON COMMUNITY SCHOOLS, INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the reports were not supported by the School Corporation's underlying accounting records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure all reports submitted on behalf of the COVID-19 - Education Stabilization Fund program funds are supported by the School Corporation's underlying accounting records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-005 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and key line items such as "Number of Specific Positions Supported with Esser Funds," "Allocation of ESSER funds," "Expenditures per Activity," and "Full-Time Equivalency Positions." During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. There was no evidence of an oversight or review process in place to prevent, or detect and correct, errors. All six reports were selected for testing. For four of the six annual data reports the report could not be traced to the records, nor could the accuracy and completeness of the reports be verified. The errors identified were as follows: The ESSER I, Year 2 report, which covered the period of October 1, 2020 to June 30, 2021, reported total expenses of $260,064. However, the School Corporation's ledger for the same period had total expenses of $264,832. Of the reported expenditures, $219,703 could not be determined to be properly categorized. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. INDIANA STATE BOARD OF ACCOUNTS 26 WASHINGTON COMMUNITY SCHOOLS, INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The ESSER I, Year 3 report, which covered the period of July 1, 2021 to June 30, 2022, reported total expenses of $86,521. However, the School Corporation's ledger for the same period had total expenses of $78,230. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The ESSER II, Year 1 and Year 2 reports, which covered the periods of July 1, 2020 to June 30, 2021, and July 1, 2021 to June 30, 2022, respectively, Key Line Items were not able to be traced to supporting documentation. The Expenditures by Subgrant Fund, expenditure category, and object code were supported by the School Corporation's records; however, the School Corporation did not provide supporting documentation for the nonfinancial data required to be submitted with the reports. The ESSER III, Year 1 report, which covered the period of July 1, 2020 to June 30, 2021, reported total expenses of $41,340. However, the School Corporation's ledger for the same period had total expenses of $20,670. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The ESSER III, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, reported total expenses of $1,407,299, which agreed to the School Corporation's ledger. However, $644,730 of the reported expenditures could not be determined to be properly categorized. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." INDIANA STATE BOARD OF ACCOUNTS 27 WASHINGTON COMMUNITY SCHOOLS, INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the reports were not supported by the School Corporation's underlying accounting records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure all reports submitted on behalf of the COVID-19 - Education Stabilization Fund program funds are supported by the School Corporation's underlying accounting records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-005 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and key line items such as "Number of Specific Positions Supported with Esser Funds," "Allocation of ESSER funds," "Expenditures per Activity," and "Full-Time Equivalency Positions." During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. There was no evidence of an oversight or review process in place to prevent, or detect and correct, errors. All six reports were selected for testing. For four of the six annual data reports the report could not be traced to the records, nor could the accuracy and completeness of the reports be verified. The errors identified were as follows: The ESSER I, Year 2 report, which covered the period of October 1, 2020 to June 30, 2021, reported total expenses of $260,064. However, the School Corporation's ledger for the same period had total expenses of $264,832. Of the reported expenditures, $219,703 could not be determined to be properly categorized. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. INDIANA STATE BOARD OF ACCOUNTS 26 WASHINGTON COMMUNITY SCHOOLS, INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The ESSER I, Year 3 report, which covered the period of July 1, 2021 to June 30, 2022, reported total expenses of $86,521. However, the School Corporation's ledger for the same period had total expenses of $78,230. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The ESSER II, Year 1 and Year 2 reports, which covered the periods of July 1, 2020 to June 30, 2021, and July 1, 2021 to June 30, 2022, respectively, Key Line Items were not able to be traced to supporting documentation. The Expenditures by Subgrant Fund, expenditure category, and object code were supported by the School Corporation's records; however, the School Corporation did not provide supporting documentation for the nonfinancial data required to be submitted with the reports. The ESSER III, Year 1 report, which covered the period of July 1, 2020 to June 30, 2021, reported total expenses of $41,340. However, the School Corporation's ledger for the same period had total expenses of $20,670. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The ESSER III, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, reported total expenses of $1,407,299, which agreed to the School Corporation's ledger. However, $644,730 of the reported expenditures could not be determined to be properly categorized. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." INDIANA STATE BOARD OF ACCOUNTS 27 WASHINGTON COMMUNITY SCHOOLS, INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the reports were not supported by the School Corporation's underlying accounting records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure all reports submitted on behalf of the COVID-19 - Education Stabilization Fund program funds are supported by the School Corporation's underlying accounting records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-005 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and key line items such as "Number of Specific Positions Supported with Esser Funds," "Allocation of ESSER funds," "Expenditures per Activity," and "Full-Time Equivalency Positions." During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. There was no evidence of an oversight or review process in place to prevent, or detect and correct, errors. All six reports were selected for testing. For four of the six annual data reports the report could not be traced to the records, nor could the accuracy and completeness of the reports be verified. The errors identified were as follows: The ESSER I, Year 2 report, which covered the period of October 1, 2020 to June 30, 2021, reported total expenses of $260,064. However, the School Corporation's ledger for the same period had total expenses of $264,832. Of the reported expenditures, $219,703 could not be determined to be properly categorized. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. INDIANA STATE BOARD OF ACCOUNTS 26 WASHINGTON COMMUNITY SCHOOLS, INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The ESSER I, Year 3 report, which covered the period of July 1, 2021 to June 30, 2022, reported total expenses of $86,521. However, the School Corporation's ledger for the same period had total expenses of $78,230. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The ESSER II, Year 1 and Year 2 reports, which covered the periods of July 1, 2020 to June 30, 2021, and July 1, 2021 to June 30, 2022, respectively, Key Line Items were not able to be traced to supporting documentation. The Expenditures by Subgrant Fund, expenditure category, and object code were supported by the School Corporation's records; however, the School Corporation did not provide supporting documentation for the nonfinancial data required to be submitted with the reports. The ESSER III, Year 1 report, which covered the period of July 1, 2020 to June 30, 2021, reported total expenses of $41,340. However, the School Corporation's ledger for the same period had total expenses of $20,670. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The ESSER III, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, reported total expenses of $1,407,299, which agreed to the School Corporation's ledger. However, $644,730 of the reported expenditures could not be determined to be properly categorized. In addition, the School Corporation was unable to provide supporting documentation for the identified Key Line Items. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." INDIANA STATE BOARD OF ACCOUNTS 27 WASHINGTON COMMUNITY SCHOOLS, INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the reports were not supported by the School Corporation's underlying accounting records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure all reports submitted on behalf of the COVID-19 - Education Stabilization Fund program funds are supported by the School Corporation's underlying accounting records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2023-022 - Inadequate Controls over Reporting and Other Federal Compliance Requirements for the Medicaid and Children’s Health Insurance Programs Award Years: 2022, 2023 Award Numbers: 2205LA5021, 2205LA5MAP, 2305LA5021, 2305LA5MAP Compliance Requirements: Matching, Earmarking, Period of Performance, Reporting Repeat Finding: No See Schedule of Findings and Questioned Costs for chart/table Condition: LDH erroneously double-reported expenditures for the Medicaid program, resulting in questioned costs, and did not complete certain quarterly checklist reviews intended to ensure compliance with the reporting and matching federal compliance requirements for the Medicaid program and the reporting, period of performance, matching, and earmarking federal compliance requirements for the CHIP program. LDH improperly included the same $16.6 million Medicaid expenditure on both the September 30, 2022, and March 31, 2023, quarterly federal expenditure reports. In addition, LDH did not complete two of the four (50%) quarterly checklist reviews for fiscal year 2023. Criteria: According to 2 CFR 200.302(b)(2), accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in 2 CFR 200.328 and 200.329 is required. The Medicaid and CHIP programs require quarterly reporting to Centers for Medicare and Medicaid Services (CMS) detailing expenditures by category of service for which states are entitled to federal reimbursement. The federal expenditures reported in the quarterly reports are used to reconcile the draws of federal funds. In addition, good internal controls require that policies and procedures are established and followed to ensure compliance with federal requirements. Cause: LDH did not ensure their controls over federal requirements were completed for every quarter during fiscal year 2023. In addition, LDH did not accurately complete the quarterly reconciliation, which is intended to ensure all items are accurately reported on the quarterly federal expenditure report. Effect: Double-reporting expenditures resulted in $14.9 million in federal questioned costs for the year ending June 30, 2023. As a result of not completing quarterly checklist reviews, LDH failed to detect the misreporting of a $1.7 million recoupment of Disproportionate Share Hospital payments on the wrong federal year schedule for the June 30, 2023, quarterly federal expenditure report. Recommendation: LDH management should strengthen controls over preparation and review of the quarterly federal expenditure reports to ensure federal expenditures are accurately reported and should ensure all quarterly checklist reviews are completed. Management’s Response and Corrective Action Plan: Management partially concurred with the finding and provided a corrective action plan (B-23). Auditor’s Additional Comments: Management's response stated, "LDH disagrees that the quarterly checklist is intended to demonstrate compliance with the federal reporting requirements." LDH management previously represented that the quarterly checklist was part of LDH's internal control process to document the preparation and review of the quarterly federal expenditure reports. As stated in the finding, the noncompliance associated with federal reporting requirements occurred because LDH did not ensure their internal controls over federal requirements were completed for every quarter during fiscal year 2023.
2023-022 - Inadequate Controls over Reporting and Other Federal Compliance Requirements for the Medicaid and Children’s Health Insurance Programs Award Years: 2022, 2023 Award Numbers: 2205LA5021, 2205LA5MAP, 2305LA5021, 2305LA5MAP Compliance Requirements: Matching, Earmarking, Period of Performance, Reporting Repeat Finding: No See Schedule of Findings and Questioned Costs for chart/table Condition: LDH erroneously double-reported expenditures for the Medicaid program, resulting in questioned costs, and did not complete certain quarterly checklist reviews intended to ensure compliance with the reporting and matching federal compliance requirements for the Medicaid program and the reporting, period of performance, matching, and earmarking federal compliance requirements for the CHIP program. LDH improperly included the same $16.6 million Medicaid expenditure on both the September 30, 2022, and March 31, 2023, quarterly federal expenditure reports. In addition, LDH did not complete two of the four (50%) quarterly checklist reviews for fiscal year 2023. Criteria: According to 2 CFR 200.302(b)(2), accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in 2 CFR 200.328 and 200.329 is required. The Medicaid and CHIP programs require quarterly reporting to Centers for Medicare and Medicaid Services (CMS) detailing expenditures by category of service for which states are entitled to federal reimbursement. The federal expenditures reported in the quarterly reports are used to reconcile the draws of federal funds. In addition, good internal controls require that policies and procedures are established and followed to ensure compliance with federal requirements. Cause: LDH did not ensure their controls over federal requirements were completed for every quarter during fiscal year 2023. In addition, LDH did not accurately complete the quarterly reconciliation, which is intended to ensure all items are accurately reported on the quarterly federal expenditure report. Effect: Double-reporting expenditures resulted in $14.9 million in federal questioned costs for the year ending June 30, 2023. As a result of not completing quarterly checklist reviews, LDH failed to detect the misreporting of a $1.7 million recoupment of Disproportionate Share Hospital payments on the wrong federal year schedule for the June 30, 2023, quarterly federal expenditure report. Recommendation: LDH management should strengthen controls over preparation and review of the quarterly federal expenditure reports to ensure federal expenditures are accurately reported and should ensure all quarterly checklist reviews are completed. Management’s Response and Corrective Action Plan: Management partially concurred with the finding and provided a corrective action plan (B-23). Auditor’s Additional Comments: Management's response stated, "LDH disagrees that the quarterly checklist is intended to demonstrate compliance with the federal reporting requirements." LDH management previously represented that the quarterly checklist was part of LDH's internal control process to document the preparation and review of the quarterly federal expenditure reports. As stated in the finding, the noncompliance associated with federal reporting requirements occurred because LDH did not ensure their internal controls over federal requirements were completed for every quarter during fiscal year 2023.
2023-022 - Inadequate Controls over Reporting and Other Federal Compliance Requirements for the Medicaid and Children’s Health Insurance Programs Award Years: 2022, 2023 Award Numbers: 2205LA5021, 2205LA5MAP, 2305LA5021, 2305LA5MAP Compliance Requirements: Matching, Earmarking, Period of Performance, Reporting Repeat Finding: No See Schedule of Findings and Questioned Costs for chart/table Condition: LDH erroneously double-reported expenditures for the Medicaid program, resulting in questioned costs, and did not complete certain quarterly checklist reviews intended to ensure compliance with the reporting and matching federal compliance requirements for the Medicaid program and the reporting, period of performance, matching, and earmarking federal compliance requirements for the CHIP program. LDH improperly included the same $16.6 million Medicaid expenditure on both the September 30, 2022, and March 31, 2023, quarterly federal expenditure reports. In addition, LDH did not complete two of the four (50%) quarterly checklist reviews for fiscal year 2023. Criteria: According to 2 CFR 200.302(b)(2), accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in 2 CFR 200.328 and 200.329 is required. The Medicaid and CHIP programs require quarterly reporting to Centers for Medicare and Medicaid Services (CMS) detailing expenditures by category of service for which states are entitled to federal reimbursement. The federal expenditures reported in the quarterly reports are used to reconcile the draws of federal funds. In addition, good internal controls require that policies and procedures are established and followed to ensure compliance with federal requirements. Cause: LDH did not ensure their controls over federal requirements were completed for every quarter during fiscal year 2023. In addition, LDH did not accurately complete the quarterly reconciliation, which is intended to ensure all items are accurately reported on the quarterly federal expenditure report. Effect: Double-reporting expenditures resulted in $14.9 million in federal questioned costs for the year ending June 30, 2023. As a result of not completing quarterly checklist reviews, LDH failed to detect the misreporting of a $1.7 million recoupment of Disproportionate Share Hospital payments on the wrong federal year schedule for the June 30, 2023, quarterly federal expenditure report. Recommendation: LDH management should strengthen controls over preparation and review of the quarterly federal expenditure reports to ensure federal expenditures are accurately reported and should ensure all quarterly checklist reviews are completed. Management’s Response and Corrective Action Plan: Management partially concurred with the finding and provided a corrective action plan (B-23). Auditor’s Additional Comments: Management's response stated, "LDH disagrees that the quarterly checklist is intended to demonstrate compliance with the federal reporting requirements." LDH management previously represented that the quarterly checklist was part of LDH's internal control process to document the preparation and review of the quarterly federal expenditure reports. As stated in the finding, the noncompliance associated with federal reporting requirements occurred because LDH did not ensure their internal controls over federal requirements were completed for every quarter during fiscal year 2023.
Condition During our audit, we examined a non statistical sample of four ERA quarterly compliance reports. We identified inaccurate information submitted for one of the reports examined. Also, for two reports examined, we were unable to complete our testing due to incomplete reports being provided. Criteria 2 CFR Sections 200.328 and 200.329 provide certain requirements for accurate financial and performance reporting. Effect Inaccurate reporting affects the accuracy and transparency of the program funds used and reported to the Department of Treasury. Cause Although the City has policies and procedures in place to ensure proper reporting, City personnel were not diligent in following procedures to ensure accurate reporting. Also due to system limitations at the Department of Treasury and a lack of retention policies, the City was unable to provide completed quarterly reports. Recommendation We recommend the City be more diligent in following its policies and procedures for submitting quarterly information to the Department of Treasury. We also recommend the City implement retention procedures to track the reports and supporting information submitted to the Department of Treasury.
Condition: During our audit procedures, we noted that the following financial reports were not submitted on time. Criteria: As stated in the award terms 2.CFR 200.328, financial reports are due on a quarterly basis. Cause: The primary cause attributed to the reporting finding regarding late submissions can be identified as a deficiency in personnel resources within Centro Margarita, Inc. The Corporation has experienced challenges in adequately staffing its finance and accounting department, thereby impeding its ability to fulfill reporting requirements in a timely and accurate manner. Effect: Late submissions of required financial reports can result in heightened scrutiny from Federal awarding agencies. The Corporation could face delays in receiving future funding until compliance issues are resolved, impacting its financial stability and mission delivery. Recommendation: Centro Margarita, Inc. should establish clear protocols and timelines for the preparation and submission of financial reports to ensure compliance with Federal awarding agency requirements. This includes recruiting more personnel, defining roles and responsibilities within the finance and accounting team and setting deadlines well in advance of the reporting due dates.
Condition: During our audit procedures, we noted that the following financial reports were not submitted on time. Criteria: As stated in the award terms 2.CFR 200.328, financial reports are due on a quarterly basis. Cause: The primary cause attributed to the reporting finding regarding late submissions can be identified as a deficiency in personnel resources within Centro Margarita, Inc. The Corporation has experienced challenges in adequately staffing its finance and accounting department, thereby impeding its ability to fulfill reporting requirements in a timely and accurate manner. Effect: Late submissions of required financial reports can result in heightened scrutiny from Federal awarding agencies. The Corporation could face delays in receiving future funding until compliance issues are resolved, impacting its financial stability and mission delivery. Recommendation: Centro Margarita, Inc. should establish clear protocols and timelines for the preparation and submission of financial reports to ensure compliance with Federal awarding agency requirements. This includes recruiting more personnel, defining roles and responsibilities within the finance and accounting team and setting deadlines well in advance of the reporting due dates.
Condition: During our audit procedures, we noted that the following financial reports were not submitted on time and/or with incorrect balances of cumulative expenses. Criteria: As stated in the award terms 2.CFR 200.328, financial reports are due on a quarterly basis. Cause: Staff members responsible for compiling and submitting financial reports may lack a comprehensive understanding of the specific reporting requirements stipulated by the Federal awarding agency. Without clear guidance or training on reporting deadlines, formatting, and content expectations, they may confront problems meeting compliance obligations in a timely and accurate manner. Effect: Late submissions of required financial reports can result in heightened scrutiny from Federal awarding agencies. The Corporation could face delays in receiving future funding until compliance issues are resolved, impacting its financial stability and mission delivery. Recommendation: Centro Margarita, Inc. should establish clear protocols and timelines for the preparation and submission of financial reports to ensure compliance with Federal awarding agency requirements. This include defining roles and responsibilities within the finance and accounting team and setting deadlines well in advance of the reporting due dates.
Finding 2023-002 – SF-425 Financial Reporting Criteria: The code of federal regulations requires that grantees submit accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements, set forth in § 200.328 and 200.329. Questioned Costs: None Condition: The City's internal controls over required reporting requirements were not accurately monitored and reviewed to prevent, or detect and correct the current year's actual federal spending. Cause and Effect: The City transitioned into a city manager type of government during fiscal year 2023. In connection with the change in political term, a significant change in personnel occurred during the time of transition affecting the City's internal controls. As a result, expenditures reported in the SF-425 financial reports submitted were understated by a total of approximately $209,000. Recommendation: We recommend that the City implement policies and procedures to ensure accurate reports are submitted to its respective agencies. Management Response: The City agrees with the recommendation. Although inaccuracies are mostly due to change in personnel, management will make a greater effort to submit complete and accurate reports.
Finding 2023-002 – SF-425 Financial Reporting Criteria: The code of federal regulations requires that grantees submit accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements, set forth in § 200.328 and 200.329. Questioned Costs: None Condition: The City's internal controls over required reporting requirements were not accurately monitored and reviewed to prevent, or detect and correct the current year's actual federal spending. Cause and Effect: The City transitioned into a city manager type of government during fiscal year 2023. In connection with the change in political term, a significant change in personnel occurred during the time of transition affecting the City's internal controls. As a result, expenditures reported in the SF-425 financial reports submitted were understated by a total of approximately $209,000. Recommendation: We recommend that the City implement policies and procedures to ensure accurate reports are submitted to its respective agencies. Management Response: The City agrees with the recommendation. Although inaccuracies are mostly due to change in personnel, management will make a greater effort to submit complete and accurate reports.
Finding 2023-002 – SF-425 Financial Reporting Criteria: The code of federal regulations requires that grantees submit accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements, set forth in § 200.328 and 200.329. Questioned Costs: None Condition: The City's internal controls over required reporting requirements were not accurately monitored and reviewed to prevent, or detect and correct the current year's actual federal spending. Cause and Effect: The City transitioned into a city manager type of government during fiscal year 2023. In connection with the change in political term, a significant change in personnel occurred during the time of transition affecting the City's internal controls. As a result, expenditures reported in the SF-425 financial reports submitted were understated by a total of approximately $209,000. Recommendation: We recommend that the City implement policies and procedures to ensure accurate reports are submitted to its respective agencies. Management Response: The City agrees with the recommendation. Although inaccuracies are mostly due to change in personnel, management will make a greater effort to submit complete and accurate reports.
Finding 2023-002 – SF-425 Financial Reporting Criteria: The code of federal regulations requires that grantees submit accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements, set forth in § 200.328 and 200.329. Questioned Costs: None Condition: The City's internal controls over required reporting requirements were not accurately monitored and reviewed to prevent, or detect and correct the current year's actual federal spending. Cause and Effect: The City transitioned into a city manager type of government during fiscal year 2023. In connection with the change in political term, a significant change in personnel occurred during the time of transition affecting the City's internal controls. As a result, expenditures reported in the SF-425 financial reports submitted were understated by a total of approximately $209,000. Recommendation: We recommend that the City implement policies and procedures to ensure accurate reports are submitted to its respective agencies. Management Response: The City agrees with the recommendation. Although inaccuracies are mostly due to change in personnel, management will make a greater effort to submit complete and accurate reports.
Finding 2023-002 – SF-425 Financial Reporting Criteria: The code of federal regulations requires that grantees submit accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements, set forth in § 200.328 and 200.329. Questioned Costs: None Condition: The City's internal controls over required reporting requirements were not accurately monitored and reviewed to prevent, or detect and correct the current year's actual federal spending. Cause and Effect: The City transitioned into a city manager type of government during fiscal year 2023. In connection with the change in political term, a significant change in personnel occurred during the time of transition affecting the City's internal controls. As a result, expenditures reported in the SF-425 financial reports submitted were understated by a total of approximately $209,000. Recommendation: We recommend that the City implement policies and procedures to ensure accurate reports are submitted to its respective agencies. Management Response: The City agrees with the recommendation. Although inaccuracies are mostly due to change in personnel, management will make a greater effort to submit complete and accurate reports.
2023-003 – Reporting – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Institutional Portion Criteria – Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds under HEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition/context – A sample of 4 special reports from the population of 4 special reports was selected. For the three quarterly reports selected, the College could not provide support that the reports were published timely. In addition, the College could not provide consistent institutional records for the data included in the three quarterly reports or annual report. Three of the four quarterly reports were corrected based on the audit procedures performed, the College did not properly identify these as “corrected” upon posting to the College website. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – Due to the lack of controls, the College did not maintain support that quarterly reports were posted timely and was unable to provide consistent institutional records for the data included in the reports. Repeat finding – Yes, 2022-005 Recommendation – We recommend the College update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report, note the reports as “corrected” and ensure institutional records are maintained that clearly support the data reported. We also recommend the College implement a process to ensure evidence of submission dates and publication dates are maintained to ensure compliance with the reporting due dates. Views of responsible officials and planned corrective actions – 93 Responsible Individuals: Dr. Lorelle Davies, Chief Financial Officer Courtney Judah, Executive Director of Institutional Effectiveness Corrective Action Plan: The college will continue to apply a detailed reporting process for timely collection and reporting of grants. Reporting to include the following: Accurate and regular collection of data needed to report outcomes and service populations. Cross verify data with Institutional Effectiveness and Institutional Research. Post in accordance with grant requirements including documentation to record posting and submission dates. Anticipated Completion Date: Completed April 30, 2024
2023-003 – Reporting – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Institutional Portion Criteria – Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds under HEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition/context – A sample of 4 special reports from the population of 4 special reports was selected. For the three quarterly reports selected, the College could not provide support that the reports were published timely. In addition, the College could not provide consistent institutional records for the data included in the three quarterly reports or annual report. Three of the four quarterly reports were corrected based on the audit procedures performed, the College did not properly identify these as “corrected” upon posting to the College website. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – Due to the lack of controls, the College did not maintain support that quarterly reports were posted timely and was unable to provide consistent institutional records for the data included in the reports. Repeat finding – Yes, 2022-005 Recommendation – We recommend the College update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report, note the reports as “corrected” and ensure institutional records are maintained that clearly support the data reported. We also recommend the College implement a process to ensure evidence of submission dates and publication dates are maintained to ensure compliance with the reporting due dates. Views of responsible officials and planned corrective actions – 93 Responsible Individuals: Dr. Lorelle Davies, Chief Financial Officer Courtney Judah, Executive Director of Institutional Effectiveness Corrective Action Plan: The college will continue to apply a detailed reporting process for timely collection and reporting of grants. Reporting to include the following: Accurate and regular collection of data needed to report outcomes and service populations. Cross verify data with Institutional Effectiveness and Institutional Research. Post in accordance with grant requirements including documentation to record posting and submission dates. Anticipated Completion Date: Completed April 30, 2024
2023-01 - Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: The Code of Federal Regulation (CFR) Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal agency provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance. Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets.Condition: During management’s preparation of the Schedule of Expenditures of Federal Awards (SEFA), the finance team of the Organization used a combination of cost center reports that identify Federal dollars spent throughout the year, reporting done by program management, and invoices billed to Federal agencies. The SEFA preparation and review process did not appropriately reflect total Federal Expenditures for the period covered. During our major program grant population completeness procedures, we identified expenditures of federal awards that had been excluded from the SEFA prepared by management. The SEFA, as presented in these financial statements has been adjusted to include an additional $13,012 of expenditures incurred for AL 93.391 versus what had been previously presented. Cause: Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain program management positions with the responsibility for submission and preparation of data for completion of the schedule of expenditures of federal awards (SEFA). As a result of these changes in staffing, management was unable to fully execute on its documented internal control policies regarding SEFA preparation. Accordingly, internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to personnel changes in the programmatic areas, responsible for submission of costs incurred for the SEFA. Effect: The SEFA provided for the audit was inaccurate for the reasons outlined in the condition section above. Failure to accurately report expenditures and programs on the SEFA result in audit adjustments. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above. Repeat Finding: This is a repeat finding. Recommendation: We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed, and that policies and procedures are followed on a consistent basis. This will ensure that Federal funds are reported accurately on the SEFA.Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action. The Organization’s corrective action plan is described in Management’s Corrective Action Plan included at page __ of this reporting package.
2023-01 - Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: The Code of Federal Regulation (CFR) Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal agency provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance. Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets.Condition: During management’s preparation of the Schedule of Expenditures of Federal Awards (SEFA), the finance team of the Organization used a combination of cost center reports that identify Federal dollars spent throughout the year, reporting done by program management, and invoices billed to Federal agencies. The SEFA preparation and review process did not appropriately reflect total Federal Expenditures for the period covered. During our major program grant population completeness procedures, we identified expenditures of federal awards that had been excluded from the SEFA prepared by management. The SEFA, as presented in these financial statements has been adjusted to include an additional $13,012 of expenditures incurred for AL 93.391 versus what had been previously presented. Cause: Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain program management positions with the responsibility for submission and preparation of data for completion of the schedule of expenditures of federal awards (SEFA). As a result of these changes in staffing, management was unable to fully execute on its documented internal control policies regarding SEFA preparation. Accordingly, internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to personnel changes in the programmatic areas, responsible for submission of costs incurred for the SEFA. Effect: The SEFA provided for the audit was inaccurate for the reasons outlined in the condition section above. Failure to accurately report expenditures and programs on the SEFA result in audit adjustments. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above. Repeat Finding: This is a repeat finding. Recommendation: We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed, and that policies and procedures are followed on a consistent basis. This will ensure that Federal funds are reported accurately on the SEFA.Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action. The Organization’s corrective action plan is described in Management’s Corrective Action Plan included at page __ of this reporting package.
2023-01 - Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: The Code of Federal Regulation (CFR) Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal agency provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance. Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets.Condition: During management’s preparation of the Schedule of Expenditures of Federal Awards (SEFA), the finance team of the Organization used a combination of cost center reports that identify Federal dollars spent throughout the year, reporting done by program management, and invoices billed to Federal agencies. The SEFA preparation and review process did not appropriately reflect total Federal Expenditures for the period covered. During our major program grant population completeness procedures, we identified expenditures of federal awards that had been excluded from the SEFA prepared by management. The SEFA, as presented in these financial statements has been adjusted to include an additional $13,012 of expenditures incurred for AL 93.391 versus what had been previously presented. Cause: Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain program management positions with the responsibility for submission and preparation of data for completion of the schedule of expenditures of federal awards (SEFA). As a result of these changes in staffing, management was unable to fully execute on its documented internal control policies regarding SEFA preparation. Accordingly, internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to personnel changes in the programmatic areas, responsible for submission of costs incurred for the SEFA. Effect: The SEFA provided for the audit was inaccurate for the reasons outlined in the condition section above. Failure to accurately report expenditures and programs on the SEFA result in audit adjustments. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above. Repeat Finding: This is a repeat finding. Recommendation: We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed, and that policies and procedures are followed on a consistent basis. This will ensure that Federal funds are reported accurately on the SEFA.Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action. The Organization’s corrective action plan is described in Management’s Corrective Action Plan included at page __ of this reporting package.
2023-01 - Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: The Code of Federal Regulation (CFR) Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal agency provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance. Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets.Condition: During management’s preparation of the Schedule of Expenditures of Federal Awards (SEFA), the finance team of the Organization used a combination of cost center reports that identify Federal dollars spent throughout the year, reporting done by program management, and invoices billed to Federal agencies. The SEFA preparation and review process did not appropriately reflect total Federal Expenditures for the period covered. During our major program grant population completeness procedures, we identified expenditures of federal awards that had been excluded from the SEFA prepared by management. The SEFA, as presented in these financial statements has been adjusted to include an additional $13,012 of expenditures incurred for AL 93.391 versus what had been previously presented. Cause: Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain program management positions with the responsibility for submission and preparation of data for completion of the schedule of expenditures of federal awards (SEFA). As a result of these changes in staffing, management was unable to fully execute on its documented internal control policies regarding SEFA preparation. Accordingly, internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to personnel changes in the programmatic areas, responsible for submission of costs incurred for the SEFA. Effect: The SEFA provided for the audit was inaccurate for the reasons outlined in the condition section above. Failure to accurately report expenditures and programs on the SEFA result in audit adjustments. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above. Repeat Finding: This is a repeat finding. Recommendation: We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed, and that policies and procedures are followed on a consistent basis. This will ensure that Federal funds are reported accurately on the SEFA.Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action. The Organization’s corrective action plan is described in Management’s Corrective Action Plan included at page __ of this reporting package.
2023-01 - Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: The Code of Federal Regulation (CFR) Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal agency provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance. Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets.Condition: During management’s preparation of the Schedule of Expenditures of Federal Awards (SEFA), the finance team of the Organization used a combination of cost center reports that identify Federal dollars spent throughout the year, reporting done by program management, and invoices billed to Federal agencies. The SEFA preparation and review process did not appropriately reflect total Federal Expenditures for the period covered. During our major program grant population completeness procedures, we identified expenditures of federal awards that had been excluded from the SEFA prepared by management. The SEFA, as presented in these financial statements has been adjusted to include an additional $13,012 of expenditures incurred for AL 93.391 versus what had been previously presented. Cause: Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain program management positions with the responsibility for submission and preparation of data for completion of the schedule of expenditures of federal awards (SEFA). As a result of these changes in staffing, management was unable to fully execute on its documented internal control policies regarding SEFA preparation. Accordingly, internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to personnel changes in the programmatic areas, responsible for submission of costs incurred for the SEFA. Effect: The SEFA provided for the audit was inaccurate for the reasons outlined in the condition section above. Failure to accurately report expenditures and programs on the SEFA result in audit adjustments. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above. Repeat Finding: This is a repeat finding. Recommendation: We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed, and that policies and procedures are followed on a consistent basis. This will ensure that Federal funds are reported accurately on the SEFA.Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action. The Organization’s corrective action plan is described in Management’s Corrective Action Plan included at page __ of this reporting package.
2023-01 - Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: The Code of Federal Regulation (CFR) Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal agency provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance. Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets.Condition: During management’s preparation of the Schedule of Expenditures of Federal Awards (SEFA), the finance team of the Organization used a combination of cost center reports that identify Federal dollars spent throughout the year, reporting done by program management, and invoices billed to Federal agencies. The SEFA preparation and review process did not appropriately reflect total Federal Expenditures for the period covered. During our major program grant population completeness procedures, we identified expenditures of federal awards that had been excluded from the SEFA prepared by management. The SEFA, as presented in these financial statements has been adjusted to include an additional $13,012 of expenditures incurred for AL 93.391 versus what had been previously presented. Cause: Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain program management positions with the responsibility for submission and preparation of data for completion of the schedule of expenditures of federal awards (SEFA). As a result of these changes in staffing, management was unable to fully execute on its documented internal control policies regarding SEFA preparation. Accordingly, internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to personnel changes in the programmatic areas, responsible for submission of costs incurred for the SEFA. Effect: The SEFA provided for the audit was inaccurate for the reasons outlined in the condition section above. Failure to accurately report expenditures and programs on the SEFA result in audit adjustments. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above. Repeat Finding: This is a repeat finding. Recommendation: We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed, and that policies and procedures are followed on a consistent basis. This will ensure that Federal funds are reported accurately on the SEFA.Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action. The Organization’s corrective action plan is described in Management’s Corrective Action Plan included at page __ of this reporting package.
2023-01 - Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: The Code of Federal Regulation (CFR) Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal agency provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance. Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets.Condition: During management’s preparation of the Schedule of Expenditures of Federal Awards (SEFA), the finance team of the Organization used a combination of cost center reports that identify Federal dollars spent throughout the year, reporting done by program management, and invoices billed to Federal agencies. The SEFA preparation and review process did not appropriately reflect total Federal Expenditures for the period covered. During our major program grant population completeness procedures, we identified expenditures of federal awards that had been excluded from the SEFA prepared by management. The SEFA, as presented in these financial statements has been adjusted to include an additional $13,012 of expenditures incurred for AL 93.391 versus what had been previously presented. Cause: Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain program management positions with the responsibility for submission and preparation of data for completion of the schedule of expenditures of federal awards (SEFA). As a result of these changes in staffing, management was unable to fully execute on its documented internal control policies regarding SEFA preparation. Accordingly, internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to personnel changes in the programmatic areas, responsible for submission of costs incurred for the SEFA. Effect: The SEFA provided for the audit was inaccurate for the reasons outlined in the condition section above. Failure to accurately report expenditures and programs on the SEFA result in audit adjustments. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above. Repeat Finding: This is a repeat finding. Recommendation: We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed, and that policies and procedures are followed on a consistent basis. This will ensure that Federal funds are reported accurately on the SEFA.Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action. The Organization’s corrective action plan is described in Management’s Corrective Action Plan included at page __ of this reporting package.
2023-01 - Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: The Code of Federal Regulation (CFR) Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal agency provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance. Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets.Condition: During management’s preparation of the Schedule of Expenditures of Federal Awards (SEFA), the finance team of the Organization used a combination of cost center reports that identify Federal dollars spent throughout the year, reporting done by program management, and invoices billed to Federal agencies. The SEFA preparation and review process did not appropriately reflect total Federal Expenditures for the period covered. During our major program grant population completeness procedures, we identified expenditures of federal awards that had been excluded from the SEFA prepared by management. The SEFA, as presented in these financial statements has been adjusted to include an additional $13,012 of expenditures incurred for AL 93.391 versus what had been previously presented. Cause: Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain program management positions with the responsibility for submission and preparation of data for completion of the schedule of expenditures of federal awards (SEFA). As a result of these changes in staffing, management was unable to fully execute on its documented internal control policies regarding SEFA preparation. Accordingly, internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to personnel changes in the programmatic areas, responsible for submission of costs incurred for the SEFA. Effect: The SEFA provided for the audit was inaccurate for the reasons outlined in the condition section above. Failure to accurately report expenditures and programs on the SEFA result in audit adjustments. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above. Repeat Finding: This is a repeat finding. Recommendation: We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed, and that policies and procedures are followed on a consistent basis. This will ensure that Federal funds are reported accurately on the SEFA.Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action. The Organization’s corrective action plan is described in Management’s Corrective Action Plan included at page __ of this reporting package.
2023-01 - Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: The Code of Federal Regulation (CFR) Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal agency provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance. Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets.Condition: During management’s preparation of the Schedule of Expenditures of Federal Awards (SEFA), the finance team of the Organization used a combination of cost center reports that identify Federal dollars spent throughout the year, reporting done by program management, and invoices billed to Federal agencies. The SEFA preparation and review process did not appropriately reflect total Federal Expenditures for the period covered. During our major program grant population completeness procedures, we identified expenditures of federal awards that had been excluded from the SEFA prepared by management. The SEFA, as presented in these financial statements has been adjusted to include an additional $13,012 of expenditures incurred for AL 93.391 versus what had been previously presented. Cause: Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain program management positions with the responsibility for submission and preparation of data for completion of the schedule of expenditures of federal awards (SEFA). As a result of these changes in staffing, management was unable to fully execute on its documented internal control policies regarding SEFA preparation. Accordingly, internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to personnel changes in the programmatic areas, responsible for submission of costs incurred for the SEFA. Effect: The SEFA provided for the audit was inaccurate for the reasons outlined in the condition section above. Failure to accurately report expenditures and programs on the SEFA result in audit adjustments. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above. Repeat Finding: This is a repeat finding. Recommendation: We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed, and that policies and procedures are followed on a consistent basis. This will ensure that Federal funds are reported accurately on the SEFA.Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action. The Organization’s corrective action plan is described in Management’s Corrective Action Plan included at page __ of this reporting package.
2023-01 - Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: The Code of Federal Regulation (CFR) Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal agency provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance. Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets.Condition: During management’s preparation of the Schedule of Expenditures of Federal Awards (SEFA), the finance team of the Organization used a combination of cost center reports that identify Federal dollars spent throughout the year, reporting done by program management, and invoices billed to Federal agencies. The SEFA preparation and review process did not appropriately reflect total Federal Expenditures for the period covered. During our major program grant population completeness procedures, we identified expenditures of federal awards that had been excluded from the SEFA prepared by management. The SEFA, as presented in these financial statements has been adjusted to include an additional $13,012 of expenditures incurred for AL 93.391 versus what had been previously presented. Cause: Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain program management positions with the responsibility for submission and preparation of data for completion of the schedule of expenditures of federal awards (SEFA). As a result of these changes in staffing, management was unable to fully execute on its documented internal control policies regarding SEFA preparation. Accordingly, internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to personnel changes in the programmatic areas, responsible for submission of costs incurred for the SEFA. Effect: The SEFA provided for the audit was inaccurate for the reasons outlined in the condition section above. Failure to accurately report expenditures and programs on the SEFA result in audit adjustments. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above. Repeat Finding: This is a repeat finding. Recommendation: We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed, and that policies and procedures are followed on a consistent basis. This will ensure that Federal funds are reported accurately on the SEFA.Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action. The Organization’s corrective action plan is described in Management’s Corrective Action Plan included at page __ of this reporting package.
2023-01 - Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: The Code of Federal Regulation (CFR) Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal agency provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance. Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets.Condition: During management’s preparation of the Schedule of Expenditures of Federal Awards (SEFA), the finance team of the Organization used a combination of cost center reports that identify Federal dollars spent throughout the year, reporting done by program management, and invoices billed to Federal agencies. The SEFA preparation and review process did not appropriately reflect total Federal Expenditures for the period covered. During our major program grant population completeness procedures, we identified expenditures of federal awards that had been excluded from the SEFA prepared by management. The SEFA, as presented in these financial statements has been adjusted to include an additional $13,012 of expenditures incurred for AL 93.391 versus what had been previously presented. Cause: Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain program management positions with the responsibility for submission and preparation of data for completion of the schedule of expenditures of federal awards (SEFA). As a result of these changes in staffing, management was unable to fully execute on its documented internal control policies regarding SEFA preparation. Accordingly, internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to personnel changes in the programmatic areas, responsible for submission of costs incurred for the SEFA. Effect: The SEFA provided for the audit was inaccurate for the reasons outlined in the condition section above. Failure to accurately report expenditures and programs on the SEFA result in audit adjustments. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above. Repeat Finding: This is a repeat finding. Recommendation: We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed, and that policies and procedures are followed on a consistent basis. This will ensure that Federal funds are reported accurately on the SEFA.Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action. The Organization’s corrective action plan is described in Management’s Corrective Action Plan included at page __ of this reporting package.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with CFR §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
Reference Number: 2023-002 Prior Year Finding: No Federal Agency: U.S. Department of Treasury Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: ARP17SL1 (5/23/2021 - 12/31/2026) Compliance Requirement: Earmarking and Reporting Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Compliance: Earmarking – Under Treasury’s Final Rule that became effective on April 1, 2022, recipients can calculate lost revenue for the years 2020, 2021, 2022, and 2023 based on the formula provided in the Final Rule to determine the amount of State and Local Fiscal Recovery Funds (SLFRF) that can be used for the “provision of government services.” To calculate revenue loss at each of these dates, recipients must follow a four-step process which includes: a. Calculate revenues collected in the most recent full fiscal year prior to the public health emergency (i.e., last full fiscal year before January 27, 2020), called the base year revenue. b. Estimate counterfactual revenue, which is equal to the following formula, where n is the number of months elapsed since the end of the base year to the calculation date: base year revenue x (1 + growth adjustment) n/12. The growth adjustment is the greater of either a standard growth rate—5.2 percent—or the recipient’s average annual revenue growth in the last full three fiscal years prior to the COVID-19 public health emergency. c. Identify actual revenue, which equals revenues collected over the twelve months immediately preceding the calculation date. d. Revenue loss for the calculation date is equal to counterfactual revenue minus actual revenue (adjusted for tax changes) for the twelve-month period. Further, the Final Rule defines the term general revenue to include revenues collected by a recipient and generated from its underlying economy and would capture a range of different types of tax revenues, as well as other types of revenue that are available to support government services. In calculating revenue, recipients should sum across all revenue streams covered as general revenue. Reporting – Per 2 CFR 200.328 and 31 CFR section 35.4(c), States, territories, metropolitan cities, counties, and Tribal governments were required to submit one interim report and quarterly Project and Expenditure reports thereafter. A Key Line Item containing critical information, as defined by Treasury, in these reports is the Revenue Replacement section. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Prince George’s County (the County) did not calculate their revenue loss in accordance with the Final Rule. As a result, amounts reported under the Revenue Replacement section of the Project and Expenditure reports were inaccurate for all quarters within the fiscal year ended June 30, 2023 Context: The County used incorrect base year revenues in their revenue loss calculation. Only general fund revenue was used in the calculation instead of summing across all revenue streams as defined by the Final Rule. Further, the County used an incorrect growth rate of 4.0% instead of 5.2% as required by the Final Rule. The Revenue Replacement section of the Project and Expenditure reports were inaccurate due to these errors. Cause: The County’s policies and procedures were not sufficient to ensure that their revenue loss calculation was in accordance with the Final Rule and that accurate information was reported in their Project and Expenditure reports under the Revenue Replacement section. Effect: The County was not in compliance with federal requirements, and failure to comply with those requirements could jeopardize future funding. Questioned costs: Undetermined. Recommendation: We recommend that the County revise the revenue loss calculation to be in accordance with the U.S. Treasury’s guidance as outlined by the Final Rule and submit a revised Project and Expenditure report to the U.S. Treasury’s SLFRF portal. Views of responsible officials: At the time that the Office of Management and Budget (OMB) calculated the revenue loss it was unclear whether it applied to only general funds or all funds. Guidance from the U.S. Treasury Department was updated frequently following enactment of the American Rescue Plan Act of 2021. Based on the finding of the audit that revenue loss calculation is not in accord with the Final Rule, OMB staff re-calculated the data using all funds.
Reference Number: 2023-002 Prior Year Finding: No Federal Agency: U.S. Department of Treasury Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: ARP17SL1 (5/23/2021 - 12/31/2026) Compliance Requirement: Earmarking and Reporting Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Compliance: Earmarking – Under Treasury’s Final Rule that became effective on April 1, 2022, recipients can calculate lost revenue for the years 2020, 2021, 2022, and 2023 based on the formula provided in the Final Rule to determine the amount of State and Local Fiscal Recovery Funds (SLFRF) that can be used for the “provision of government services.” To calculate revenue loss at each of these dates, recipients must follow a four-step process which includes: a. Calculate revenues collected in the most recent full fiscal year prior to the public health emergency (i.e., last full fiscal year before January 27, 2020), called the base year revenue. b. Estimate counterfactual revenue, which is equal to the following formula, where n is the number of months elapsed since the end of the base year to the calculation date: base year revenue x (1 + growth adjustment) n/12. The growth adjustment is the greater of either a standard growth rate—5.2 percent—or the recipient’s average annual revenue growth in the last full three fiscal years prior to the COVID-19 public health emergency. c. Identify actual revenue, which equals revenues collected over the twelve months immediately preceding the calculation date. d. Revenue loss for the calculation date is equal to counterfactual revenue minus actual revenue (adjusted for tax changes) for the twelve-month period. Further, the Final Rule defines the term general revenue to include revenues collected by a recipient and generated from its underlying economy and would capture a range of different types of tax revenues, as well as other types of revenue that are available to support government services. In calculating revenue, recipients should sum across all revenue streams covered as general revenue. Reporting – Per 2 CFR 200.328 and 31 CFR section 35.4(c), States, territories, metropolitan cities, counties, and Tribal governments were required to submit one interim report and quarterly Project and Expenditure reports thereafter. A Key Line Item containing critical information, as defined by Treasury, in these reports is the Revenue Replacement section. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Prince George’s County (the County) did not calculate their revenue loss in accordance with the Final Rule. As a result, amounts reported under the Revenue Replacement section of the Project and Expenditure reports were inaccurate for all quarters within the fiscal year ended June 30, 2023 Context: The County used incorrect base year revenues in their revenue loss calculation. Only general fund revenue was used in the calculation instead of summing across all revenue streams as defined by the Final Rule. Further, the County used an incorrect growth rate of 4.0% instead of 5.2% as required by the Final Rule. The Revenue Replacement section of the Project and Expenditure reports were inaccurate due to these errors. Cause: The County’s policies and procedures were not sufficient to ensure that their revenue loss calculation was in accordance with the Final Rule and that accurate information was reported in their Project and Expenditure reports under the Revenue Replacement section. Effect: The County was not in compliance with federal requirements, and failure to comply with those requirements could jeopardize future funding. Questioned costs: Undetermined. Recommendation: We recommend that the County revise the revenue loss calculation to be in accordance with the U.S. Treasury’s guidance as outlined by the Final Rule and submit a revised Project and Expenditure report to the U.S. Treasury’s SLFRF portal. Views of responsible officials: At the time that the Office of Management and Budget (OMB) calculated the revenue loss it was unclear whether it applied to only general funds or all funds. Guidance from the U.S. Treasury Department was updated frequently following enactment of the American Rescue Plan Act of 2021. Based on the finding of the audit that revenue loss calculation is not in accord with the Final Rule, OMB staff re-calculated the data using all funds.
Reference Number: 2023-002 Prior Year Finding: No Federal Agency: U.S. Department of Treasury Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: ARP17SL1 (5/23/2021 - 12/31/2026) Compliance Requirement: Earmarking and Reporting Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Compliance: Earmarking – Under Treasury’s Final Rule that became effective on April 1, 2022, recipients can calculate lost revenue for the years 2020, 2021, 2022, and 2023 based on the formula provided in the Final Rule to determine the amount of State and Local Fiscal Recovery Funds (SLFRF) that can be used for the “provision of government services.” To calculate revenue loss at each of these dates, recipients must follow a four-step process which includes: a. Calculate revenues collected in the most recent full fiscal year prior to the public health emergency (i.e., last full fiscal year before January 27, 2020), called the base year revenue. b. Estimate counterfactual revenue, which is equal to the following formula, where n is the number of months elapsed since the end of the base year to the calculation date: base year revenue x (1 + growth adjustment) n/12. The growth adjustment is the greater of either a standard growth rate—5.2 percent—or the recipient’s average annual revenue growth in the last full three fiscal years prior to the COVID-19 public health emergency. c. Identify actual revenue, which equals revenues collected over the twelve months immediately preceding the calculation date. d. Revenue loss for the calculation date is equal to counterfactual revenue minus actual revenue (adjusted for tax changes) for the twelve-month period. Further, the Final Rule defines the term general revenue to include revenues collected by a recipient and generated from its underlying economy and would capture a range of different types of tax revenues, as well as other types of revenue that are available to support government services. In calculating revenue, recipients should sum across all revenue streams covered as general revenue. Reporting – Per 2 CFR 200.328 and 31 CFR section 35.4(c), States, territories, metropolitan cities, counties, and Tribal governments were required to submit one interim report and quarterly Project and Expenditure reports thereafter. A Key Line Item containing critical information, as defined by Treasury, in these reports is the Revenue Replacement section. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Prince George’s County (the County) did not calculate their revenue loss in accordance with the Final Rule. As a result, amounts reported under the Revenue Replacement section of the Project and Expenditure reports were inaccurate for all quarters within the fiscal year ended June 30, 2023 Context: The County used incorrect base year revenues in their revenue loss calculation. Only general fund revenue was used in the calculation instead of summing across all revenue streams as defined by the Final Rule. Further, the County used an incorrect growth rate of 4.0% instead of 5.2% as required by the Final Rule. The Revenue Replacement section of the Project and Expenditure reports were inaccurate due to these errors. Cause: The County’s policies and procedures were not sufficient to ensure that their revenue loss calculation was in accordance with the Final Rule and that accurate information was reported in their Project and Expenditure reports under the Revenue Replacement section. Effect: The County was not in compliance with federal requirements, and failure to comply with those requirements could jeopardize future funding. Questioned costs: Undetermined. Recommendation: We recommend that the County revise the revenue loss calculation to be in accordance with the U.S. Treasury’s guidance as outlined by the Final Rule and submit a revised Project and Expenditure report to the U.S. Treasury’s SLFRF portal. Views of responsible officials: At the time that the Office of Management and Budget (OMB) calculated the revenue loss it was unclear whether it applied to only general funds or all funds. Guidance from the U.S. Treasury Department was updated frequently following enactment of the American Rescue Plan Act of 2021. Based on the finding of the audit that revenue loss calculation is not in accord with the Final Rule, OMB staff re-calculated the data using all funds.
2023-001 U.S. Department of Treasury & Passed through the Commonwealth of Massachusetts Executive Office of Public Safety and Homeland Security COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – AL# 21.027 Criteria: Per 2 CFR section 200.328 of the Uniform Guidance, each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the federal awarding agency. The compliance supplement identifies four Key Line Items required to be reported to the federal awarding agency which include (1) current period obligation, (2) cumulative obligation, (3) current period expenditure and (4) cumulative expenditure. Condition: As of the June 30, 2023 reporting date, the City’s Project and Expenditure Reports understated expenditures by $629,040. Also, obligations were overstated by approximately $15,000,000. Cause: The City did not reconcile the Project and Expenditure report with the City’s general ledger before submitting. The City also considered City departments as subrecipients which caused them to report departmental agreements as obligations. Effect: The City did not properly report grant expenditures and obligations in the Project and Expenditure reporting. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2022-002 Recommendation: The City should implement procedures to reconcile the financial information in the Project and Expenditure reports to the City’s general ledger and contract files before submission. Views of Responsible Official: Management agrees with the finding, but notes that there was confusion with the US Treasury portal and the City reached out to the US Treasury and received clarification on reporting obligations moving forward. Additionally, the US Treasury issued in November 2023 the Obligation Interim Final Rule to address questions and comments regarding the definition of obligation by recipients. In addition, it revises the definition of “obligation” in US Treasury’s SLFRF program. Anticipated completion date of the corrective action is April 30, 2024.
2023-001 U.S. Department of Treasury & Passed through the Commonwealth of Massachusetts Executive Office of Public Safety and Homeland Security COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – AL# 21.027 Criteria: Per 2 CFR section 200.328 of the Uniform Guidance, each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the federal awarding agency. The compliance supplement identifies four Key Line Items required to be reported to the federal awarding agency which include (1) current period obligation, (2) cumulative obligation, (3) current period expenditure and (4) cumulative expenditure. Condition: As of the June 30, 2023 reporting date, the City’s Project and Expenditure Reports understated expenditures by $629,040. Also, obligations were overstated by approximately $15,000,000. Cause: The City did not reconcile the Project and Expenditure report with the City’s general ledger before submitting. The City also considered City departments as subrecipients which caused them to report departmental agreements as obligations. Effect: The City did not properly report grant expenditures and obligations in the Project and Expenditure reporting. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2022-002 Recommendation: The City should implement procedures to reconcile the financial information in the Project and Expenditure reports to the City’s general ledger and contract files before submission. Views of Responsible Official: Management agrees with the finding, but notes that there was confusion with the US Treasury portal and the City reached out to the US Treasury and received clarification on reporting obligations moving forward. Additionally, the US Treasury issued in November 2023 the Obligation Interim Final Rule to address questions and comments regarding the definition of obligation by recipients. In addition, it revises the definition of “obligation” in US Treasury’s SLFRF program. Anticipated completion date of the corrective action is April 30, 2024.
2023-001 U.S. Department of Treasury & Passed through the Commonwealth of Massachusetts Executive Office of Public Safety and Homeland Security COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – AL# 21.027 Criteria: Per 2 CFR section 200.328 of the Uniform Guidance, each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the federal awarding agency. The compliance supplement identifies four Key Line Items required to be reported to the federal awarding agency which include (1) current period obligation, (2) cumulative obligation, (3) current period expenditure and (4) cumulative expenditure. Condition: As of the June 30, 2023 reporting date, the City’s Project and Expenditure Reports understated expenditures by $629,040. Also, obligations were overstated by approximately $15,000,000. Cause: The City did not reconcile the Project and Expenditure report with the City’s general ledger before submitting. The City also considered City departments as subrecipients which caused them to report departmental agreements as obligations. Effect: The City did not properly report grant expenditures and obligations in the Project and Expenditure reporting. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2022-002 Recommendation: The City should implement procedures to reconcile the financial information in the Project and Expenditure reports to the City’s general ledger and contract files before submission. Views of Responsible Official: Management agrees with the finding, but notes that there was confusion with the US Treasury portal and the City reached out to the US Treasury and received clarification on reporting obligations moving forward. Additionally, the US Treasury issued in November 2023 the Obligation Interim Final Rule to address questions and comments regarding the definition of obligation by recipients. In addition, it revises the definition of “obligation” in US Treasury’s SLFRF program. Anticipated completion date of the corrective action is April 30, 2024.