Condition: The organization could not provide copies of periodic financial and performance reports submitted to the federal awarding agency or pass‐through entity for the ERA program. Criteria: 2 CFR 200.328 requires non‐federal entities to submit accurate and timely financial and performance reports to the awarding agency. Cause: The absence of policies and procedures for maintaining these records resulted in their unavailability during the audit. Effect: Failure to maintain these reports limits the ability to substantiate compliance with the reporting requirements. Recommendation: Develop and implement procedures to ensure financial and performance reports are prepared, reviewed, and retained. Questioned Costs: None Management’s Response: Management acknowledges the need to address and enhance this area finding. We are committed to implementing new procedures for recording and tracking program income, including documenting its source, amount, and application. These procedures will be put in place within three months, with oversight provided by senior management to ensure proper compliance and effective implementation.
Federal Agency: United States Department of Commerce Federal Program Name: Office for Coastal Management Assistance Listing Number: 11.473 Federal Award Identification Year: 2020 Pass-Through Agency: National Fish and Wildlife Grant Agreement Award Period: 9/1/20-08/31/23 Type of Finding: Other Matters - Significant Deficiency in Internal Control Criteria: 2 CFR 200.328 - Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB approved, governmentwide data elements available from the OMB designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. 2 CFR 200.329(c)(1) -Requirements state that the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or passthrough entity to best inform improvements in program outcomes and productivity. Condition: For one of the two reports selected for testing, CFSC did not submit the reports to the National Fish and Wildlife Foundation by the required date. Context: A nonstatistical sample of 2 out of 4 required reports were selected for testing for the Office for Coastal Management program. The condition noted above was identified during our procedures over the CFSC’s reporting requirements. Effect: CFSC did not submit required reports in a timely manner, increasing the risk of noncompliance. Cause: CFSC’s procedures did not consistently ensure that the required reports were submitted on a timely basis. Repeat Finding: The finding is a repeat finding. Recommendation: We recommend that management modify and strengthen its current policies and procedures to ensure that all required reports are submitted on a timely basis to the appropriate Federal Agency or Pass-Through Entity. Management’s Views: See separate corrective action plan.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass- through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreement for McConnelsville NRG Sewer Facility Improvements (B-F-19-1CA-1) state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), one out of one (one hundred percent) of Status Reports were submitted seven months late. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass- through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreement for McConnelsville NRG Sewer Facility Improvements (B-F-19-1CA-1) state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), one out of one (one hundred percent) of Status Reports were submitted seven months late. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass- through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreement for McConnelsville NRG Sewer Facility Improvements (B-F-19-1CA-1) state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), one out of one (one hundred percent) of Status Reports were submitted seven months late. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass- through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreement for McConnelsville NRG Sewer Facility Improvements (B-F-19-1CA-1) state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), one out of one (one hundred percent) of Status Reports were submitted seven months late. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
FINDING 2022-003 Information on the federal program: Subject: Water and Waste Disposal Systems for Rural Communities – Reporting Federal Agency: U.S. Department of Agriculture Assistance Listing Number: 10.760 Federal Award Number: 92-02 92-03 Pass-Through Entity: N/A Compliance Requirements: Reporting Audit Findings: Significant Deficiency Criteria: 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: The City did not have proper controls in place to ensure that the annual report was accurately filled out and agreed to underlying detail. Cause: There were not sufficient internal controls in place to ensure the accuracy of the annual report prior to its submission. Effect: The failure to establish an effective internal control system placed the City at risk of noncompliance with the grant agreement and the Reporting compliance requirements. Questioned Costs: There were no questioned costs identified. Context: Variances to key line items were noted when comparing the Form RD442-2 and Form RD442-3 to supporting documents. Identification as a repeat finding, if applicable: No Recommendation: We recommend someone other than the preparer thoroughly review and document the review of the report prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, 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). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, 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). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, 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). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, 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). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, 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). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, 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). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, 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). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Compliance Requirement: L Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late. Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period). Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance. Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance. Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: L Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late. Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period). Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance. Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance. Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: L Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late. Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period). Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance. Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance. Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: L Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late. Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period). Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance. Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance. Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: L Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late. Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period). Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance. Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance. Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: L Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late. Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period). Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance. Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance. Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: L Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late. Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period). Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance. Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance. Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 200.208 states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreements for the Village of Lafayette Water Line Project (B-W-20-1AB-1), the Gomer Wastewater Collection System Project (B-W-1AB-3) and Village of Harrod Water Line Project (B-W-20-1AB-2), state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however, three out of six (fifty percent) Status Reports were submitted between three to six months late and for one out of six (sixteen percent) Status Reports the receipts and expenditures did not agree to the County records. Reporting errors could adversely affect future grant awards. A control system should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
Community Development Financial Institutions Rapid Response Program (CDFI RRP), Assistance Listing Number: 21.024 U.S. Department of the Treasury Program Year 2022 Criteria or specific requirement – Reporting (2 CFR section 200.328 and 200.329) Condition – The Credit Union reported the incorrect amount of cumulative awards expended in the 2022 Use of Awards Report. Cause – The Credit Union’s controls did not ensure the proper amounts were reported. Effect – The Credit Union reported the incorrect amount of awards expended during 2022. Questioned costs – N/A Context – The Credit Union is required to submit three reports for the year ended December 31, 2022. All of the required reports were tested. The 2022 Use of Awards report reported $828,265 as the cumulative use of award, rather than the actual total cumulative use of $1,826,265 that was actually expended during the year. Identification as a repeat finding, if applicable – N/A Recommendation – Management should review and update controls over federal grant reporting to ensure reports are prepared using complete and accurate information. Views of responsible officials and planned corrective actions – The input error was corrected prior to end of the audit. The credit union's CDFI analyst was contacted by the Chief Strategic Officer and the analyst opened the data field for editing in the AMIS system. The Chief Strategic Officer made the correction in the AMIS system and submitted the corrected information. The Chief Strategic Officer has assigned CDFI reporting responsibilities to the Director of Strategy. Future submissions will be performed by the Director of Strategy and reviewed by the Chief Strategic Officer prior to submission.
Finding 2022-004 Compliance Requirement: Internal Control over Compliance and Compliance with Reporting (Preparation of Schedule of Expenditures of Federal Awards) Prior Year Finding Number: N/A Program: ALN 14.267 U.S. Department of Housing and Urban Development – Continuum of Care Program ALN 16.575 U.S. Department of Justice – Victims of Crime Acts Program ALN 21.027 U.S. Department of Treasury – Victims of Crime Acts Program 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 (SEFA) 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 SEFA must provide total federal awards expended for each individual Federal program. In accordance with Section 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 entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (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 Section 200.328 Financial Reporting and Section 200.329 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition – The SEFA as prepared by management did not originally include one federal grant with federal expenditures during the year and one grant for which the Assistance Listing Number (ALN) did not match the grant documents. Cause - The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to new funding received in the current year. Effect – The original SEFA was incomplete. Questioned Costs: None. Context: The conditions outlined above are based on our testing of the Organization’s major program and our overall testing of the accuracy of the SEFA. The nature of this findings is detailed in the condition section above. Recommendation- We recommend management attend federal award trainings and information to ensure the documented policies and procedures can be performed as described. This will ensure the federal funds are reported accurately on the SEFA and that programs are reported under the correct ALN. Views of Responsible Officials – The Organization concurs with the auditor’s findings and recommendations. The Organization will continue to review federal award guidance and requirements to ensure compliance with current and future federal awards. Refer to the Organization’s corrective action plan for further details.
Finding 2022-004 Compliance Requirement: Internal Control over Compliance and Compliance with Reporting (Preparation of Schedule of Expenditures of Federal Awards) Prior Year Finding Number: N/A Program: ALN 14.267 U.S. Department of Housing and Urban Development – Continuum of Care Program ALN 16.575 U.S. Department of Justice – Victims of Crime Acts Program ALN 21.027 U.S. Department of Treasury – Victims of Crime Acts Program 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 (SEFA) 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 SEFA must provide total federal awards expended for each individual Federal program. In accordance with Section 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 entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (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 Section 200.328 Financial Reporting and Section 200.329 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition – The SEFA as prepared by management did not originally include one federal grant with federal expenditures during the year and one grant for which the Assistance Listing Number (ALN) did not match the grant documents. Cause - The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to new funding received in the current year. Effect – The original SEFA was incomplete. Questioned Costs: None. Context: The conditions outlined above are based on our testing of the Organization’s major program and our overall testing of the accuracy of the SEFA. The nature of this findings is detailed in the condition section above. Recommendation- We recommend management attend federal award trainings and information to ensure the documented policies and procedures can be performed as described. This will ensure the federal funds are reported accurately on the SEFA and that programs are reported under the correct ALN. Views of Responsible Officials – The Organization concurs with the auditor’s findings and recommendations. The Organization will continue to review federal award guidance and requirements to ensure compliance with current and future federal awards. Refer to the Organization’s corrective action plan for further details.
Finding 2022-004 Compliance Requirement: Internal Control over Compliance and Compliance with Reporting (Preparation of Schedule of Expenditures of Federal Awards) Prior Year Finding Number: N/A Program: ALN 14.267 U.S. Department of Housing and Urban Development – Continuum of Care Program ALN 16.575 U.S. Department of Justice – Victims of Crime Acts Program ALN 21.027 U.S. Department of Treasury – Victims of Crime Acts Program 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 (SEFA) 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 SEFA must provide total federal awards expended for each individual Federal program. In accordance with Section 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 entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (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 Section 200.328 Financial Reporting and Section 200.329 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition – The SEFA as prepared by management did not originally include one federal grant with federal expenditures during the year and one grant for which the Assistance Listing Number (ALN) did not match the grant documents. Cause - The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to new funding received in the current year. Effect – The original SEFA was incomplete. Questioned Costs: None. Context: The conditions outlined above are based on our testing of the Organization’s major program and our overall testing of the accuracy of the SEFA. The nature of this findings is detailed in the condition section above. Recommendation- We recommend management attend federal award trainings and information to ensure the documented policies and procedures can be performed as described. This will ensure the federal funds are reported accurately on the SEFA and that programs are reported under the correct ALN. Views of Responsible Officials – The Organization concurs with the auditor’s findings and recommendations. The Organization will continue to review federal award guidance and requirements to ensure compliance with current and future federal awards. Refer to the Organization’s corrective action plan for further details.
Finding 2022-004 Compliance Requirement: Internal Control over Compliance and Compliance with Reporting (Preparation of Schedule of Expenditures of Federal Awards) Prior Year Finding Number: N/A Program: ALN 14.267 U.S. Department of Housing and Urban Development – Continuum of Care Program ALN 16.575 U.S. Department of Justice – Victims of Crime Acts Program ALN 21.027 U.S. Department of Treasury – Victims of Crime Acts Program 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 (SEFA) 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 SEFA must provide total federal awards expended for each individual Federal program. In accordance with Section 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 entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (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 Section 200.328 Financial Reporting and Section 200.329 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition – The SEFA as prepared by management did not originally include one federal grant with federal expenditures during the year and one grant for which the Assistance Listing Number (ALN) did not match the grant documents. Cause - The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to new funding received in the current year. Effect – The original SEFA was incomplete. Questioned Costs: None. Context: The conditions outlined above are based on our testing of the Organization’s major program and our overall testing of the accuracy of the SEFA. The nature of this findings is detailed in the condition section above. Recommendation- We recommend management attend federal award trainings and information to ensure the documented policies and procedures can be performed as described. This will ensure the federal funds are reported accurately on the SEFA and that programs are reported under the correct ALN. Views of Responsible Officials – The Organization concurs with the auditor’s findings and recommendations. The Organization will continue to review federal award guidance and requirements to ensure compliance with current and future federal awards. Refer to the Organization’s corrective action plan for further details.
Finding 2022-004 Compliance Requirement: Internal Control over Compliance and Compliance with Reporting (Preparation of Schedule of Expenditures of Federal Awards) Prior Year Finding Number: N/A Program: ALN 14.267 U.S. Department of Housing and Urban Development – Continuum of Care Program ALN 16.575 U.S. Department of Justice – Victims of Crime Acts Program ALN 21.027 U.S. Department of Treasury – Victims of Crime Acts Program 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 (SEFA) 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 SEFA must provide total federal awards expended for each individual Federal program. In accordance with Section 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 entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (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 Section 200.328 Financial Reporting and Section 200.329 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition – The SEFA as prepared by management did not originally include one federal grant with federal expenditures during the year and one grant for which the Assistance Listing Number (ALN) did not match the grant documents. Cause - The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to new funding received in the current year. Effect – The original SEFA was incomplete. Questioned Costs: None. Context: The conditions outlined above are based on our testing of the Organization’s major program and our overall testing of the accuracy of the SEFA. The nature of this findings is detailed in the condition section above. Recommendation- We recommend management attend federal award trainings and information to ensure the documented policies and procedures can be performed as described. This will ensure the federal funds are reported accurately on the SEFA and that programs are reported under the correct ALN. Views of Responsible Officials – The Organization concurs with the auditor’s findings and recommendations. The Organization will continue to review federal award guidance and requirements to ensure compliance with current and future federal awards. Refer to the Organization’s corrective action plan for further details.
Finding 2022-004 Compliance Requirement: Internal Control over Compliance and Compliance with Reporting (Preparation of Schedule of Expenditures of Federal Awards) Prior Year Finding Number: N/A Program: ALN 14.267 U.S. Department of Housing and Urban Development – Continuum of Care Program ALN 16.575 U.S. Department of Justice – Victims of Crime Acts Program ALN 21.027 U.S. Department of Treasury – Victims of Crime Acts Program 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 (SEFA) 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 SEFA must provide total federal awards expended for each individual Federal program. In accordance with Section 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 entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (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 Section 200.328 Financial Reporting and Section 200.329 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition – The SEFA as prepared by management did not originally include one federal grant with federal expenditures during the year and one grant for which the Assistance Listing Number (ALN) did not match the grant documents. Cause - The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to new funding received in the current year. Effect – The original SEFA was incomplete. Questioned Costs: None. Context: The conditions outlined above are based on our testing of the Organization’s major program and our overall testing of the accuracy of the SEFA. The nature of this findings is detailed in the condition section above. Recommendation- We recommend management attend federal award trainings and information to ensure the documented policies and procedures can be performed as described. This will ensure the federal funds are reported accurately on the SEFA and that programs are reported under the correct ALN. Views of Responsible Officials – The Organization concurs with the auditor’s findings and recommendations. The Organization will continue to review federal award guidance and requirements to ensure compliance with current and future federal awards. Refer to the Organization’s corrective action plan for further details.
Criteria: In accordance with 2 CFR 200.328 and 2 CFR 200.329, the College is required to prepare and publicly post quarterly reports related to the student aid and institutional portions of HEERF expenditures. Condition: During our audit, we selected one of the four quarterly reports to test the accuracy of the reporting. Our testing indicated certain amounts on the quarterly report that did not agree to the expenditures for the quarter. Questioned Costs: None Effect: The College was not in compliance with HEERF reporting requirements. Cause: Certain HEERF I expenditures were improperly excluded from the report and some misunderstanding of requirements of certain items in the report. Recommendation: We recommend reconciliation of quarterly reports to related grant documentation and review of the reports by an appropriate team member to ensure accuracy. Views of responsible officials and planned corrective action: The College agrees with this finding and will adhere to the corrective action plan on page 34 in this audit report.
Criteria: In accordance with 2 CFR 200.328 and 2 CFR 200.329, the College is required to prepare and publicly post quarterly reports related to the student aid and institutional portions of HEERF expenditures. Condition: During our audit, we selected one of the four quarterly reports to test the accuracy of the reporting. Our testing indicated certain amounts on the quarterly report that did not agree to the expenditures for the quarter. Questioned Costs: None Effect: The College was not in compliance with HEERF reporting requirements. Cause: Certain HEERF I expenditures were improperly excluded from the report and some misunderstanding of requirements of certain items in the report. Recommendation: We recommend reconciliation of quarterly reports to related grant documentation and review of the reports by an appropriate team member to ensure accuracy. Views of responsible officials and planned corrective action: The College agrees with this finding and will adhere to the corrective action plan on page 34 in this audit report.
Criteria: In accordance with 2 CFR 200.328 and 2 CFR 200.329, the College is required to prepare and publicly post quarterly reports related to the student aid and institutional portions of HEERF expenditures. Condition: During our audit, we selected one of the four quarterly reports to test the accuracy of the reporting. Our testing indicated certain amounts on the quarterly report that did not agree to the expenditures for the quarter. Questioned Costs: None Effect: The College was not in compliance with HEERF reporting requirements. Cause: Certain HEERF I expenditures were improperly excluded from the report and some misunderstanding of requirements of certain items in the report. Recommendation: We recommend reconciliation of quarterly reports to related grant documentation and review of the reports by an appropriate team member to ensure accuracy. Views of responsible officials and planned corrective action: The College agrees with this finding and will adhere to the corrective action plan on page 34 in this audit report.
Condition: Rainbow Health Minnesota did not submit its single audit reporting package to the Federal Audit Clearinghouse within the required time frame. Criteria: 2 CFR 200.328 establishes requirements for financial grant reporting by a non-federal entity. The Organization must report financial information as required by the terms and conditions of the federal award. 2 CFR 200.512(a) requires the audit reporting package and data collection form to be submitted to the Federal Audit Clearinghouse the earlier of 30 days after the reports are received from the auditors or nine months after the end of the audit period. Cause: Employee turnover in the finance department resulted in financial and program data not being ready for the financial and single audits on a timely basis. Effect: The Organization is not in compliance with timely reporting requirements. Questioned Costs: $0 Context: Rainbow Health Minnesota did not submit its year ended December 31, 2020 audit reporting package to the Federal Audit Clearinghouse until November 4, 2021, its year ended December 31, 2021 audit reporting package until February 10, 2023 and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Rainbow Health Minnesota continue efforts to develop internal control policies and procedures over financial activities to ensure that its financial and program data is ready for the financial and single audits on a timely basis. Views of Responsible Officials and Planned Corrective Actions: We agree with this finding and have implemented the following internal control policies and procedures concerning the timeliness of financial activities: Rainbow Health Minnesota is reimplementing monthly board meetings that will include a financial review of income and expense reports and balance sheets. The lateness for the 2022 audit was partially due to staff turnover of the CFO and the subsequent review by the new Finance Director. Responsibility for administering this process resides with the Finance Director.
Condition: Rainbow Health Minnesota did not submit its single audit reporting package to the Federal Audit Clearinghouse within the required time frame. Criteria: 2 CFR 200.328 establishes requirements for financial grant reporting by a non-federal entity. The Organization must report financial information as required by the terms and conditions of the federal award. 2 CFR 200.512(a) requires the audit reporting package and data collection form to be submitted to the Federal Audit Clearinghouse the earlier of 30 days after the reports are received from the auditors or nine months after the end of the audit period. Cause: Employee turnover in the finance department resulted in financial and program data not being ready for the financial and single audits on a timely basis. Effect: The Organization is not in compliance with timely reporting requirements. Questioned Costs: $0 Context: Rainbow Health Minnesota did not submit its year ended December 31, 2020 audit reporting package to the Federal Audit Clearinghouse until November 4, 2021, its year ended December 31, 2021 audit reporting package until February 10, 2023 and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Rainbow Health Minnesota continue efforts to develop internal control policies and procedures over financial activities to ensure that its financial and program data is ready for the financial and single audits on a timely basis. Views of Responsible Officials and Planned Corrective Actions: We agree with this finding and have implemented the following internal control policies and procedures concerning the timeliness of financial activities: Rainbow Health Minnesota is reimplementing monthly board meetings that will include a financial review of income and expense reports and balance sheets. The lateness for the 2022 audit was partially due to staff turnover of the CFO and the subsequent review by the new Finance Director. Responsibility for administering this process resides with the Finance Director.
Condition: Rainbow Health Minnesota did not submit its single audit reporting package to the Federal Audit Clearinghouse within the required time frame. Criteria: 2 CFR 200.328 establishes requirements for financial grant reporting by a non-federal entity. The Organization must report financial information as required by the terms and conditions of the federal award. 2 CFR 200.512(a) requires the audit reporting package and data collection form to be submitted to the Federal Audit Clearinghouse the earlier of 30 days after the reports are received from the auditors or nine months after the end of the audit period. Cause: Employee turnover in the finance department resulted in financial and program data not being ready for the financial and single audits on a timely basis. Effect: The Organization is not in compliance with timely reporting requirements. Questioned Costs: $0 Context: Rainbow Health Minnesota did not submit its year ended December 31, 2020 audit reporting package to the Federal Audit Clearinghouse until November 4, 2021, its year ended December 31, 2021 audit reporting package until February 10, 2023 and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Rainbow Health Minnesota continue efforts to develop internal control policies and procedures over financial activities to ensure that its financial and program data is ready for the financial and single audits on a timely basis. Views of Responsible Officials and Planned Corrective Actions: We agree with this finding and have implemented the following internal control policies and procedures concerning the timeliness of financial activities: Rainbow Health Minnesota is reimplementing monthly board meetings that will include a financial review of income and expense reports and balance sheets. The lateness for the 2022 audit was partially due to staff turnover of the CFO and the subsequent review by the new Finance Director. Responsibility for administering this process resides with the Finance Director.
Condition: Rainbow Health Minnesota did not submit its single audit reporting package to the Federal Audit Clearinghouse within the required time frame. Criteria: 2 CFR 200.328 establishes requirements for financial grant reporting by a non-federal entity. The Organization must report financial information as required by the terms and conditions of the federal award. 2 CFR 200.512(a) requires the audit reporting package and data collection form to be submitted to the Federal Audit Clearinghouse the earlier of 30 days after the reports are received from the auditors or nine months after the end of the audit period. Cause: Employee turnover in the finance department resulted in financial and program data not being ready for the financial and single audits on a timely basis. Effect: The Organization is not in compliance with timely reporting requirements. Questioned Costs: $0 Context: Rainbow Health Minnesota did not submit its year ended December 31, 2020 audit reporting package to the Federal Audit Clearinghouse until November 4, 2021, its year ended December 31, 2021 audit reporting package until February 10, 2023 and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Rainbow Health Minnesota continue efforts to develop internal control policies and procedures over financial activities to ensure that its financial and program data is ready for the financial and single audits on a timely basis. Views of Responsible Officials and Planned Corrective Actions: We agree with this finding and have implemented the following internal control policies and procedures concerning the timeliness of financial activities: Rainbow Health Minnesota is reimplementing monthly board meetings that will include a financial review of income and expense reports and balance sheets. The lateness for the 2022 audit was partially due to staff turnover of the CFO and the subsequent review by the new Finance Director. Responsibility for administering this process resides with the Finance Director.
Condition: Rainbow Health Minnesota did not submit its single audit reporting package to the Federal Audit Clearinghouse within the required time frame. Criteria: 2 CFR 200.328 establishes requirements for financial grant reporting by a non-federal entity. The Organization must report financial information as required by the terms and conditions of the federal award. 2 CFR 200.512(a) requires the audit reporting package and data collection form to be submitted to the Federal Audit Clearinghouse the earlier of 30 days after the reports are received from the auditors or nine months after the end of the audit period. Cause: Employee turnover in the finance department resulted in financial and program data not being ready for the financial and single audits on a timely basis. Effect: The Organization is not in compliance with timely reporting requirements. Questioned Costs: $0 Context: Rainbow Health Minnesota did not submit its year ended December 31, 2020 audit reporting package to the Federal Audit Clearinghouse until November 4, 2021, its year ended December 31, 2021 audit reporting package until February 10, 2023 and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Rainbow Health Minnesota continue efforts to develop internal control policies and procedures over financial activities to ensure that its financial and program data is ready for the financial and single audits on a timely basis. Views of Responsible Officials and Planned Corrective Actions: We agree with this finding and have implemented the following internal control policies and procedures concerning the timeliness of financial activities: Rainbow Health Minnesota is reimplementing monthly board meetings that will include a financial review of income and expense reports and balance sheets. The lateness for the 2022 audit was partially due to staff turnover of the CFO and the subsequent review by the new Finance Director. Responsibility for administering this process resides with the Finance Director.
Condition: Rainbow Health Minnesota did not submit its single audit reporting package to the Federal Audit Clearinghouse within the required time frame. Criteria: 2 CFR 200.328 establishes requirements for financial grant reporting by a non-federal entity. The Organization must report financial information as required by the terms and conditions of the federal award. 2 CFR 200.512(a) requires the audit reporting package and data collection form to be submitted to the Federal Audit Clearinghouse the earlier of 30 days after the reports are received from the auditors or nine months after the end of the audit period. Cause: Employee turnover in the finance department resulted in financial and program data not being ready for the financial and single audits on a timely basis. Effect: The Organization is not in compliance with timely reporting requirements. Questioned Costs: $0 Context: Rainbow Health Minnesota did not submit its year ended December 31, 2020 audit reporting package to the Federal Audit Clearinghouse until November 4, 2021, its year ended December 31, 2021 audit reporting package until February 10, 2023 and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Rainbow Health Minnesota continue efforts to develop internal control policies and procedures over financial activities to ensure that its financial and program data is ready for the financial and single audits on a timely basis. Views of Responsible Officials and Planned Corrective Actions: We agree with this finding and have implemented the following internal control policies and procedures concerning the timeliness of financial activities: Rainbow Health Minnesota is reimplementing monthly board meetings that will include a financial review of income and expense reports and balance sheets. The lateness for the 2022 audit was partially due to staff turnover of the CFO and the subsequent review by the new Finance Director. Responsibility for administering this process resides with the Finance Director.
Condition: Rainbow Health Minnesota did not submit its single audit reporting package to the Federal Audit Clearinghouse within the required time frame. Criteria: 2 CFR 200.328 establishes requirements for financial grant reporting by a non-federal entity. The Organization must report financial information as required by the terms and conditions of the federal award. 2 CFR 200.512(a) requires the audit reporting package and data collection form to be submitted to the Federal Audit Clearinghouse the earlier of 30 days after the reports are received from the auditors or nine months after the end of the audit period. Cause: Employee turnover in the finance department resulted in financial and program data not being ready for the financial and single audits on a timely basis. Effect: The Organization is not in compliance with timely reporting requirements. Questioned Costs: $0 Context: Rainbow Health Minnesota did not submit its year ended December 31, 2020 audit reporting package to the Federal Audit Clearinghouse until November 4, 2021, its year ended December 31, 2021 audit reporting package until February 10, 2023 and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Rainbow Health Minnesota continue efforts to develop internal control policies and procedures over financial activities to ensure that its financial and program data is ready for the financial and single audits on a timely basis. Views of Responsible Officials and Planned Corrective Actions: We agree with this finding and have implemented the following internal control policies and procedures concerning the timeliness of financial activities: Rainbow Health Minnesota is reimplementing monthly board meetings that will include a financial review of income and expense reports and balance sheets. The lateness for the 2022 audit was partially due to staff turnover of the CFO and the subsequent review by the new Finance Director. Responsibility for administering this process resides with the Finance Director.
Condition: Rainbow Health Minnesota did not submit its single audit reporting package to the Federal Audit Clearinghouse within the required time frame. Criteria: 2 CFR 200.328 establishes requirements for financial grant reporting by a non-federal entity. The Organization must report financial information as required by the terms and conditions of the federal award. 2 CFR 200.512(a) requires the audit reporting package and data collection form to be submitted to the Federal Audit Clearinghouse the earlier of 30 days after the reports are received from the auditors or nine months after the end of the audit period. Cause: Employee turnover in the finance department resulted in financial and program data not being ready for the financial and single audits on a timely basis. Effect: The Organization is not in compliance with timely reporting requirements. Questioned Costs: $0 Context: Rainbow Health Minnesota did not submit its year ended December 31, 2020 audit reporting package to the Federal Audit Clearinghouse until November 4, 2021, its year ended December 31, 2021 audit reporting package until February 10, 2023 and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Rainbow Health Minnesota continue efforts to develop internal control policies and procedures over financial activities to ensure that its financial and program data is ready for the financial and single audits on a timely basis. Views of Responsible Officials and Planned Corrective Actions: We agree with this finding and have implemented the following internal control policies and procedures concerning the timeliness of financial activities: Rainbow Health Minnesota is reimplementing monthly board meetings that will include a financial review of income and expense reports and balance sheets. The lateness for the 2022 audit was partially due to staff turnover of the CFO and the subsequent review by the new Finance Director. Responsibility for administering this process resides with the Finance Director.
Condition: Rainbow Health Minnesota did not submit its single audit reporting package to the Federal Audit Clearinghouse within the required time frame. Criteria: 2 CFR 200.328 establishes requirements for financial grant reporting by a non-federal entity. The Organization must report financial information as required by the terms and conditions of the federal award. 2 CFR 200.512(a) requires the audit reporting package and data collection form to be submitted to the Federal Audit Clearinghouse the earlier of 30 days after the reports are received from the auditors or nine months after the end of the audit period. Cause: Employee turnover in the finance department resulted in financial and program data not being ready for the financial and single audits on a timely basis. Effect: The Organization is not in compliance with timely reporting requirements. Questioned Costs: $0 Context: Rainbow Health Minnesota did not submit its year ended December 31, 2020 audit reporting package to the Federal Audit Clearinghouse until November 4, 2021, its year ended December 31, 2021 audit reporting package until February 10, 2023 and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Rainbow Health Minnesota continue efforts to develop internal control policies and procedures over financial activities to ensure that its financial and program data is ready for the financial and single audits on a timely basis. Views of Responsible Officials and Planned Corrective Actions: We agree with this finding and have implemented the following internal control policies and procedures concerning the timeliness of financial activities: Rainbow Health Minnesota is reimplementing monthly board meetings that will include a financial review of income and expense reports and balance sheets. The lateness for the 2022 audit was partially due to staff turnover of the CFO and the subsequent review by the new Finance Director. Responsibility for administering this process resides with the Finance Director.
Condition: Rainbow Health Minnesota did not submit its single audit reporting package to the Federal Audit Clearinghouse within the required time frame. Criteria: 2 CFR 200.328 establishes requirements for financial grant reporting by a non-federal entity. The Organization must report financial information as required by the terms and conditions of the federal award. 2 CFR 200.512(a) requires the audit reporting package and data collection form to be submitted to the Federal Audit Clearinghouse the earlier of 30 days after the reports are received from the auditors or nine months after the end of the audit period. Cause: Employee turnover in the finance department resulted in financial and program data not being ready for the financial and single audits on a timely basis. Effect: The Organization is not in compliance with timely reporting requirements. Questioned Costs: $0 Context: Rainbow Health Minnesota did not submit its year ended December 31, 2020 audit reporting package to the Federal Audit Clearinghouse until November 4, 2021, its year ended December 31, 2021 audit reporting package until February 10, 2023 and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Rainbow Health Minnesota continue efforts to develop internal control policies and procedures over financial activities to ensure that its financial and program data is ready for the financial and single audits on a timely basis. Views of Responsible Officials and Planned Corrective Actions: We agree with this finding and have implemented the following internal control policies and procedures concerning the timeliness of financial activities: Rainbow Health Minnesota is reimplementing monthly board meetings that will include a financial review of income and expense reports and balance sheets. The lateness for the 2022 audit was partially due to staff turnover of the CFO and the subsequent review by the new Finance Director. Responsibility for administering this process resides with the Finance Director.
Condition: Rainbow Health Minnesota did not submit its single audit reporting package to the Federal Audit Clearinghouse within the required time frame. Criteria: 2 CFR 200.328 establishes requirements for financial grant reporting by a non-federal entity. The Organization must report financial information as required by the terms and conditions of the federal award. 2 CFR 200.512(a) requires the audit reporting package and data collection form to be submitted to the Federal Audit Clearinghouse the earlier of 30 days after the reports are received from the auditors or nine months after the end of the audit period. Cause: Employee turnover in the finance department resulted in financial and program data not being ready for the financial and single audits on a timely basis. Effect: The Organization is not in compliance with timely reporting requirements. Questioned Costs: $0 Context: Rainbow Health Minnesota did not submit its year ended December 31, 2020 audit reporting package to the Federal Audit Clearinghouse until November 4, 2021, its year ended December 31, 2021 audit reporting package until February 10, 2023 and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Rainbow Health Minnesota continue efforts to develop internal control policies and procedures over financial activities to ensure that its financial and program data is ready for the financial and single audits on a timely basis. Views of Responsible Officials and Planned Corrective Actions: We agree with this finding and have implemented the following internal control policies and procedures concerning the timeliness of financial activities: Rainbow Health Minnesota is reimplementing monthly board meetings that will include a financial review of income and expense reports and balance sheets. The lateness for the 2022 audit was partially due to staff turnover of the CFO and the subsequent review by the new Finance Director. Responsibility for administering this process resides with the Finance Director.
Condition: Rainbow Health Minnesota did not submit its single audit reporting package to the Federal Audit Clearinghouse within the required time frame. Criteria: 2 CFR 200.328 establishes requirements for financial grant reporting by a non-federal entity. The Organization must report financial information as required by the terms and conditions of the federal award. 2 CFR 200.512(a) requires the audit reporting package and data collection form to be submitted to the Federal Audit Clearinghouse the earlier of 30 days after the reports are received from the auditors or nine months after the end of the audit period. Cause: Employee turnover in the finance department resulted in financial and program data not being ready for the financial and single audits on a timely basis. Effect: The Organization is not in compliance with timely reporting requirements. Questioned Costs: $0 Context: Rainbow Health Minnesota did not submit its year ended December 31, 2020 audit reporting package to the Federal Audit Clearinghouse until November 4, 2021, its year ended December 31, 2021 audit reporting package until February 10, 2023 and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Rainbow Health Minnesota continue efforts to develop internal control policies and procedures over financial activities to ensure that its financial and program data is ready for the financial and single audits on a timely basis. Views of Responsible Officials and Planned Corrective Actions: We agree with this finding and have implemented the following internal control policies and procedures concerning the timeliness of financial activities: Rainbow Health Minnesota is reimplementing monthly board meetings that will include a financial review of income and expense reports and balance sheets. The lateness for the 2022 audit was partially due to staff turnover of the CFO and the subsequent review by the new Finance Director. Responsibility for administering this process resides with the Finance Director.
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022, Coronavirus State and Local Fiscal Recovery Funds Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award. 2 CFR 200.327 and 2 CFR 200.328 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements, to assure performance expectations are being achieved, and to report these items in accordance with program requirements. The Foundation is required to submit quarterly performance reports. Reports should be prepared complete, accurate, and in accordance with the required basis for reporting, submitted timely with the terms of the grant award, and reviewed by an individual prior to submission to ensure accuracy. Condition: Although the reports were reviewed in accordance with internal controls, the review process did not properly identify on two out of the two reports tested that they were submitted with inaccurate information. Supporting documentation for the reports submitted used budgeted expensed amounts, not actual, and the budgeted expensed amounts for the period did not agree to amounts reported. Cause: The Organization has limited staffing and did not have proper controls in place relating to review of information included in reports to ensure completeness and accuracy. Effect: Inaccurate information may be provided to the grantor regarding performance of the Foundation. Questioned Costs: None reported. Context: A nonstatistical sample of 2 out of 4 reports submitted were selected for testing. Repeat Finding from Prior Years: No Recommendation: We recommend the Foundation’s management routinely review and consider modifications that would strengthen the internal controls surrounding the reporting process, recordkeeping, and the management thereof. Specifically, management should ensure that financial records are such to provide actual amounts of grant expenditures incurred for reporting purposes at required reporting dates, and that the review control ensures that reports provided to grantors agree with internal financial records. Views of Responsible Officials: Management agrees with the finding.
2 CFR 1000.10 provides that, except for the deviations set forth elsewhere in this Part, the Department of Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards set forth at 2 CFR Part 200. 2 CFR 200.302(b) states, in part, that the financial management system of each non-Federal entity must provide for the 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. The City did not have proper internal controls in place to ensure the accurate submission of the Project and Expenditure Reports. During testing of Project and Expenditure Reports for the Coronavirus State and Local Fiscal Recovery Funds (AL #21.027), we noted that: ? The City did not properly report cumulative obligations on the report required by July 31, 2022. The City over-reported cumulative obligations due to including a funding project more than once for $880,000 to the Justice Center Design project; and ? The City did not properly report cumulative obligations nor current period expenditures on the report required by October 31, 2022. The City over-reported cumulative obligations by $880,000 due to including a funding project more than once to the Justice Center Design project. The City also over-reported current period expenditures due to including the current period expenditures of $175,741 for a funding project more than once to Rehiring Staff project. Failure to have the proper controls in place to ensure the timely and accurate submission of the Project and Expenditure Reports could result in Treasury taking action against the City for failure to comply with programmatic requirements. The City should implement and have controls in place to ensure the quarterly Project and Expenditure Reports are accurate.
2 CFR 1000.10 provides that, except for the deviations set forth elsewhere in this Part, the Department of Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards set forth at 2 CFR Part 200. 2 CFR 200.302(b) states, in part, that the financial management system of each non-Federal entity must provide for the 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. The City did not have proper internal controls in place to ensure the accurate submission of the Project and Expenditure Reports. During testing of Project and Expenditure Reports for the Coronavirus State and Local Fiscal Recovery Funds (AL #21.027), we noted that: ? The City did not properly report cumulative obligations on the report required by July 31, 2022. The City over-reported cumulative obligations due to including a funding project more than once for $880,000 to the Justice Center Design project; and ? The City did not properly report cumulative obligations nor current period expenditures on the report required by October 31, 2022. The City over-reported cumulative obligations by $880,000 due to including a funding project more than once to the Justice Center Design project. The City also over-reported current period expenditures due to including the current period expenditures of $175,741 for a funding project more than once to Rehiring Staff project. Failure to have the proper controls in place to ensure the timely and accurate submission of the Project and Expenditure Reports could result in Treasury taking action against the City for failure to comply with programmatic requirements. The City should implement and have controls in place to ensure the quarterly Project and Expenditure Reports are accurate.
2 CFR 1000.10 provides that, except for the deviations set forth elsewhere in this Part, the Department of Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards set forth at 2 CFR Part 200. 2 CFR 200.302(b) states, in part, that the financial management system of each non-Federal entity must provide for the 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. The City did not have proper internal controls in place to ensure the accurate submission of the Project and Expenditure Reports. During testing of Project and Expenditure Reports for the Coronavirus State and Local Fiscal Recovery Funds (AL #21.027), we noted that: ? The City did not properly report cumulative obligations on the report required by July 31, 2022. The City over-reported cumulative obligations due to including a funding project more than once for $880,000 to the Justice Center Design project; and ? The City did not properly report cumulative obligations nor current period expenditures on the report required by October 31, 2022. The City over-reported cumulative obligations by $880,000 due to including a funding project more than once to the Justice Center Design project. The City also over-reported current period expenditures due to including the current period expenditures of $175,741 for a funding project more than once to Rehiring Staff project. Failure to have the proper controls in place to ensure the timely and accurate submission of the Project and Expenditure Reports could result in Treasury taking action against the City for failure to comply with programmatic requirements. The City should implement and have controls in place to ensure the quarterly Project and Expenditure Reports are accurate.
2022-002 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 State Assistance Listing Number: 19.706 Assistance Listing Name: Partnership for Regional East Africa Counterterrorism Award Numbers: Direct Award Numbers Award Period SLMAQM20CA2264 September 28, 2020 through March 29, 2024 SLMAQM20GR2364 September 28, 2020 through September 30, 2024 Criteria: 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 ?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 entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (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 ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition: The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management?s preparation of the SEFA, BDO identified two awards whose assistance listing number was changed by the federal entity in award amendments issued prior to December 31, 2022. Management failed to update the assistance listing number for the awards within the SEFA to address the award modifications. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not fully operate as designed. The Organization did not adequately review award modifications for changes to existing awards. Effect: The SEFA initially provided to BDO resulted in incorrect major program selection as prescribed under the Unform Guidance. During the review of the award agreements, BDO identified the assistance listing numbers for the two awards had been modified. This issue resulted in a different major program selection once the SEFA was updated to reflect the correct assistance listing numbers. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management to continue to focus on training for both preparer and reviewers of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section ?200.510(b). This will ensure that the SEFA provides all relevant information as proscribed.
2022-002 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 State Assistance Listing Number: 19.706 Assistance Listing Name: Partnership for Regional East Africa Counterterrorism Award Numbers: Direct Award Numbers Award Period SLMAQM20CA2264 September 28, 2020 through March 29, 2024 SLMAQM20GR2364 September 28, 2020 through September 30, 2024 Criteria: 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 ?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 entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (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 ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition: The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management?s preparation of the SEFA, BDO identified two awards whose assistance listing number was changed by the federal entity in award amendments issued prior to December 31, 2022. Management failed to update the assistance listing number for the awards within the SEFA to address the award modifications. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not fully operate as designed. The Organization did not adequately review award modifications for changes to existing awards. Effect: The SEFA initially provided to BDO resulted in incorrect major program selection as prescribed under the Unform Guidance. During the review of the award agreements, BDO identified the assistance listing numbers for the two awards had been modified. This issue resulted in a different major program selection once the SEFA was updated to reflect the correct assistance listing numbers. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management to continue to focus on training for both preparer and reviewers of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section ?200.510(b). This will ensure that the SEFA provides all relevant information as proscribed.