State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of the Treasury (TREAS) Program Name: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds ALN and Program Expenditures 21.027 ($2,804,581,453) Award Numbers: Various - see table of award numbers Federal Award Year: Various - see table of award numbers Questioned Costs: None Compliance Requirement: Reporting Finding 2023-003: Failure to Accurately Prepare Performance Reports for the COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Program Condition Found: GOMB did not prepare accurate federal project and expenditure reports (Paperwork Reduction Act (PRA) 1505-0271) for the COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program. The State was required to prepare quarterly federal project and expenditure reports (PRA 1505-0271) for the CSLFRF program. To assist the State agencies, GOMB prepared these reports. According to the U.S. Treasury’s SLFRF Compliance and Reporting Guidance, expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. During our testing of two quarterly PRA 1505-0271 reports submitted during State fiscal year ended June 30, 2023, we noted that GOMB did not consistently apply cash or accrual basis for reporting and noted the following errors on the cash basis: "See Table in the Audit Report". Supervisory review procedures of the PRA 1505-0271 reports have not been designed to operate at an appropriate level of precision to ensure the financial reports are accurately prepared. Criteria or Requirement: 2 CFR 200.328 requires grantees to submit PRA 1505-0271 reports with the frequency required by the terms and conditions of the federal award. The State and Local Fiscal Recovery Funds: Project and Expenditure Report User Guide requires grantees to submit quarterly reports with current financial information, including current period and cumulative obligations and expenditures. In addition, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure financial information reported in required financial reports is complete and accurate prior to submission. Cause: In discussing these conditions with GOMB officials, management stated the reporting errors were a result of inaccurate information submitted to GOMB by other State agencies which were not detected. Possible Asserted Effect: Failure to prepare complete and accurate financial reports prevents the U.S. Treasury from effectively monitoring the CSLFRF program. Repeat Finding: A similar finding was not reported in the prior year audit. (Finding Code 2023-003) Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB implement more precise review procedures to ensure the reports submitted to the U.S. Treasury are complete, accurate, and agree or reconcile to its financial records. Views of GOMB Officials: GOMB agrees with the recommendation. GOMB will continue to work with the State agencies to produce accurate financial reporting for the CSLFRF program.
State Agency: Illinois Department of Human Services (IDHS) Federal Agency: U.S. Department of the Treasury (TREAS) Program Name: COVID-19 – Homeowner Assistance Fund Program ALN and Program Expenditures: 21.026 ($177,107,928) Award Numbers: Various - see table of award numbers Federal Award Year: Various - see table of award numbers Questioned Costs: None Compliance Requirement: Reporting Finding 2023-005: Failure to Accurately Prepare Financial Reports for the COVID-19 – Homeowner Assistance Fund Program Condition Found: IDHS did not prepare accurate federal financial reports (Paperwork Reduction Act (PRA) 1505-0269) for the COVID-19 – Homeowner Assistance Fund (HAF) program. IDHS was required to prepare quarterly federal financial reports (PRA 1505-0269) for the HAF program. During our testing of two quarterly PRA 1505-0269 reports submitted during State fiscal year ended June 30, 2023, we noted the following errors: "See Table in the Audit Report". Supervisory review procedures of the PRA 1505-0269 reports have not been designed to operate at an appropriate level of precision to ensure the financial reports are accurately prepared. Criteria or Requirement: 2 CFR 200.328 requires grantees to submit PRA 1505-0269 reports with the frequency required by the terms and conditions of the federal award. The Homeowner Assistance Fund: Quarterly Report User Guide requires grantees to submit quarterly reports with current financial information, including administrative expenses. In addition, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure financial information reported in required financial reports is complete and accurate prior to submission. Cause: In discussing these conditions with IDHS officials, management stated that during the reporting period sampled, the 3rd quarter report was the first group of program data reported. Due to limited availability of staff at that time, the Department was still working to identify appropriate staff to complete the reporting. Possible Asserted Effect: Failure to prepare complete and accurate financial reports prevents U.S. Treasury from effectively monitoring the HAF program. Repeat Finding: A similar finding was not reported in prior years. (Finding Code 2023-005) Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend IDHS implement more precise review procedures to ensure the reports submitted to U.S. Treasury are complete, accurate, and agree or reconcile to its financial records. Views of IDHS Officials: The Department accepts the recommendation. The Department recognizes the need for accurate data submissions and now has standard templates for subrecipients to complete to ensure accurate program reporting is achieved.
FINDING 2023-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit an annual data report to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were prepared by the Treasurer and reviewed by a second knowledgeable individual; however, this process did not allow for the prevention, or detection and correction, of errors prior to submission. Due to the lack of effective internal controls, one of the six annual data reports was not supported by the School Corporation's records. For the ESSER III, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, total expenses per the report were $688,778. However, the School Corporation's ledger had total expenses for the award, for that time period, of $784,638. INDIANA STATE BOARD OF ACCOUNTS 18 OAK HILL UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of internal controls and noncompliance were isolated to the ESSER III, Year 2 report. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III, Year 2 report was not supported by the School Corporation's records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. 19 INDIANA STATE BOARD OF ACCOUNTS OAK HILL UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all expenditures are reported on the reports submitted on behalf of the COVID-19 - Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit an annual data report to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were prepared by the Treasurer and reviewed by a second knowledgeable individual; however, this process did not allow for the prevention, or detection and correction, of errors prior to submission. Due to the lack of effective internal controls, one of the six annual data reports was not supported by the School Corporation's records. For the ESSER III, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, total expenses per the report were $688,778. However, the School Corporation's ledger had total expenses for the award, for that time period, of $784,638. INDIANA STATE BOARD OF ACCOUNTS 18 OAK HILL UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of internal controls and noncompliance were isolated to the ESSER III, Year 2 report. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III, Year 2 report was not supported by the School Corporation's records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. 19 INDIANA STATE BOARD OF ACCOUNTS OAK HILL UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all expenditures are reported on the reports submitted on behalf of the COVID-19 - Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Federal Agency: U.S. Department of Homeland Security Pass-Through Agency: Central Office of Recovery, Reconstruction and Resiliency of Puerto Rico (COR3) Program: Disaster Grants – Public Assistance (Presidentially-Declared Disaster) (ALN 97.036) Compliance Requirement: Reporting (L) Type of Finding: Significant Deficiency in Internal Control (SD), Instance of Noncompliance (NC) Statement of Condition In our Reporting Test, we evaluated the Quarterly Progress Reports of a total of five (5) projects for two quarters of fiscal year 2022-2023. Our audit procedures revealed that Quarterly Progress Reports were not submitted for one of the quarters for four of the five projects evaluated. Criteria 2 CFR 200.328 (c) states that the recipient or subrecipient must submit financial reports as required by the Federal award. […] Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. 2 CFR 200.329 (c) (1) states that the recipient or subrecipient must submit performance reports as required by the Federal award. […] Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. […] 2 CFR 200.332 (b) (3) states that any additional requirements that the pass-through entity imposes on the subrecipient for the pass-through entity to meet its responsibilities under the Federal award. This includes information and certifications […] required for submitting financial and performance reports that the pass-through entity must provide to the Federal agency. 44 CFR 206.204 (f) states that progress reports will be submitted by the recipient to the Regional Administrator quarterly. […] COR3, as a pass-through entity, requires Subrecipients to complete and submit a quarterly progress report for each Project Worksheet (“PW”) through the Disaster Recovery Solution (“DRS”) Platform. This information is then submitted to the Federal Emergency Management Agency (FEMA). Quarterly Progress Reports cannot be edited or submitted after the deadline. Cause of Condition The Municipality did not manage time effectively to complete the Quarterly Progress Reports as required by the Federal award. Effect of Condition The Municipality failed in the submission of Quarterly Progress Reports as required by the Federal award. Recommendation We recommend the Program Administrators manage time effectively to complete the Quarterly Progress Reports timely. Questioned Costs None. Views of Responsible Officials and Planned Corrective Action We will give instructions to the accounting staff in charge of the preparation of the quarterly progress reports of the Program, in order to comply with the FEMA reporting requirements. Responsible Official: Mrs. Irma M. Vargas Aguirre, Finance and Budget Director Implementation Date: December 31, 2025
Name: Schools and Roads – Grants to States Assistance Listing #:10.665 Federal Grantor: U.S. Department of Agriculture Pass-Through Entity: State Controller’s Office Award No.: Various Year: 2022-23 Compliance Requirement: Reporting Criteria: Per 2 CFR 200.328 and program-specific requirements under the Secure Rural Schools and Community Self-Determination Act (Public Law 110-343, as amended), counties receiving Title III funds must annually certify the amount of funds expended and the amount of unobligated funds by February 1 following the end of the Federal fiscal year. The certification must be submitted to the appropriate U.S. Forest Service Regional Office. Condition: For the fiscal year ended June 30, 2023, the County did not file the required Certification of Title III Expenditures and Unobligated Funds by the statutory deadline of February 1, 2024. Cause: The County did not have adequate procedures in place to track and ensure timely completion and submission of required federal reports for Title III funds. Effect: Failure to submit the certification may result in noncompliance with federal requirements and could lead to future ineligibility for Title III funds or required return of unobligated funds. Questioned Cost: No questioned costs were identified as a result of our procedures. Context: The condition noted above was identified during our procedures related to compliance testing over the major program identified above. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the County establish internal control procedures to ensure that required certifications for Title III expenditures and unobligated funds are completed, reviewed, and submitted timely in accordance with federal requirements. Views of Responsible Officials and Planned Corrective Action: Refer to separate Managements’ Corrective Action Plan for views of responsible officials and management’s responses.
Name: Epidemioloy and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing #: 93.323 Federal Grantor: U.S. Department of Health and Human Services Pass-Through Entity: State Department of Public Health Award No.: 19-ELC32 and 19-ELC90 Year: 2022-23 Compliance Requirement: Reporting Criteria: Per 2 CFR 200.327 and 200.328, recipients of federal awards must submit required financial and performance reports by the due dates specified in the award terms and conditions. The Notice of Award for ALN 93.323 requires the submission of monthly and quarterly expenditure and progress reports within 30 days after the end of each reporting period. Condition: During audit testing, it was noted that a majority of the required reports were not submitted within the required 30 day timeframe. Documentation provided by the grantee confirmed that the reports were filed late. Cause: The delays occurred due to staff turnover within the Plumas County Department of Health. Effect: Failure to submit required reports in a timely manner may hinder the federal agency's ability to monitor financial and program performance, increasing the risk of delayed reimbursement or potential noncompliance with grant requirements. Questioned Cost: No questioned costs were identified as a result of our procedures. Context: The condition noted above was identified during our procedures related to compliance testing over the major program identified above. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management establish and enforce procedures to ensure all required federal financial and progress reports are submitted by the applicable due dates. Views of Responsible Officials and Planned Corrective Action: Refer to separate Managements’ Corrective Action Plan for views of responsible officials and management’s responses.
2023-008 Improve Controls and Compliance with Reporting Federal Program Information Federal Agency: U.S. Department of Treasury Award Name(s): COVID-19 Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number(s): 21.027 Award Year: 2023 Compliance Requirement: Reporting Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement Recipients of American Rescue Plan Act (ARPA) State and Local Fiscal Recovery Funds are required by Uniform Guidance (2 CFR § 200.328–200.329) and program requirements to submit accurate and timely quarterly performance and evaluation reports to the federal awarding agency. The City must maintain documentation supporting the submission and content of required reports as part of effective internal control over compliance. Condition and Context As part of our testing of the ARPA program, the City was unable to provide the requested quarterly performance and evaluation reports as required to be submitted under the program. Cause The City did not have adequate controls in place to ensure the timely preparation, submission, and retention of required quarterly performance and evaluation reports. Effect or Potential Effect Failure to prepare, submit, and retain quarterly performance and evaluation reports results in noncompliance with ARPA program requirements and undermines transparency and accountability for federal funds received. Questioned Costs No questioned costs are reported. Identification as a Repeat Finding This was not a finding in the prior year. Recommendation The City should establish and implement formal procedures to ensure all required quarterly performance and evaluation reports are prepared, submitted, and retained in accordance with program requirements. SECTION III – FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (CONTINUED) Management should regularly monitor compliance with reporting deadlines and maintain adequate documentation. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
2023-010 Improve Controls and Compliance with Reporting Federal Program Information Federal Agency: U.S. Department of Housing and Urban Development Award Name(s): CDBG Entitlement Grants Cluster Assistance Listing Number(s): 14.218 Award Year: 2023 Compliance Requirement: Reporting Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement Per Uniform Guidance (2 CFR § 200.328–200.329) and program-specific requirements for Community Development Block Grants/Entitlement Grants, recipients must submit required financial and programmatic reports accurately and timely to the federal awarding agency. Effective internal controls must be in place to ensure compliance with all reporting deadlines. Condition and Context The City did not file required financial and programmatic reports in a timely manner as stipulated under the grant program. Multiple reports were submitted after their respective deadlines, including the Consolidated Annual Performance and Evaluation Report (CAPER) which is required to be submitted 90 days after the close of a jurisdiction’s program year but was actually submitted in October of 2025. SECTION III – FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (CONTINUED) Cause The City lacked adequate internal controls and procedures to ensure timely preparation, review, and submission of required reports to the federal awarding agency. Effect or Potential Effect Failure to file financial and programmatic reports on time constitutes noncompliance with federal program requirements and reduces transparency and accountability regarding the use of federal funds. Questioned Costs No questioned costs are reported. Identification as a Repeat Finding This is a repeat of prior year finding 2022-005. Recommendation The City should establish and implement formal procedures and controls to monitor reporting deadlines, ensure timely completion and submission of required financial and programmatic reports, and maintain documentation evidencing compliance with all reporting requirements. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
FINDING 2023-005 Subject: Title I Grants to Local Educational Agencies - Earmarking Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A200014, S010A210014, S010A220014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Match, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 26 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context Earmarking A portion of the School Corporation's Title I allocation is required to be reserved for parental involvement and homeless reservation, as specified in the Title I grant application. The School Corporation is responsible for monitoring these set-asides throughout the grant period to ensure compliance. While monitoring was completed on the reimbursement requests, the requests, though reviewed by a knowledgeable employee, were supported by summary level payroll data. This level of detail was insufficient to confirm that the appropriate employees were charged to the designated Title I funds. Additionally, the School Corporation did not spend the Homeless Student set-aside amount per the Title I application and did not carry over the funds to provide services to students experiencing homelessness in the subsequent school year, along with reserving funds from the next year's grant award. The lack of internal controls and noncompliance was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." INDIANA STATE BOARD OF ACCOUNTS 27 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 20 USC 6313(c)(3)(A) states: "A local educational agency shall reserve such funds as are necessary under this part, determined in accordance with subparagraphs (B) and (C), to provide services comparable to those provided to children in schools funded under this part to serve - (i) homeless children and youths, including providing educationally related support services to children in shelters and other locations where children may live; (ii) children in local institutions for neglected children; and (iii) if appropriate, children in local institutions for delinquent children, and neglected or delinquent children in community day programs." Cause The School Corporation did not have adequate internal controls to ensure compliance with Title I set-aside requirements. Monitoring procedures relied on summary level payroll documentation, which did not provide sufficient detail to verify that employees charged to Title I were allowable and properly assigned. Additionally, the School Corporation lacked a formal process to track, monitor, and ensure timely use or carryover of the Homeless Student set-aside funds, resulting in noncompliance with the approved Title I application. Effect The lack of detailed payroll documentation and insufficient monitoring of Title I set-asides resulted in the School Corporation being unable to demonstrate that payroll expenditures charged to Title I were accurate, allowable, or aligned with the approved grant budget. The failure to spend or carry over the required Homeless Student set-aside funds limits services available to students' experiencing homelessness. These deficiencies increase the risk of questioned costs, required corrective actions, and potential restrictions on future grant funding, while also creating additional administrative burden during the audit due to the need for expanded testing and follow-up. Questioned Costs There were no questioned costs identified. Recommendation The School Corporation should strengthen internal controls by requiring detailed, employee-level payroll documentation to support all Title I charges and ensure reviewers verify that expenditures align with the approved grant budget. In addition, the School Corporation should implement a formal process to track all Title I set-asides, including parental involvement and homeless reservations, throughout the grant period. Procedures should also be established to ensure the timely use or proper carryover of homeless student set-aside funds in accordance with federal regulations and the approved Title I application. Additionally, the School Corporation should provide necessary support and resources to staff responsible for ensuring grant compliance and helping to prevent similar issues in future grant cycles. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-006 Subject: Title I Grants to Local Educational Agencies - Reporting Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A200014, S010A210014, S010A220014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-004. Condition and Context The School Corporation was required to submit reimbursement requests and final expenditure reports that included, among other data, both current and prior period expenditures. However, the required reports for federal awards did not capture all activity for the reporting period and were not supported by the School Corporation's records. Reimbursement Requests The School Corporation uses reimbursement requests to claim allowable expenses paid from Title I funds. These requests must be based on and supported by transactions recorded within the School Corporation's Title I accounts. Summary-level reports were generated from the School Corporation's financial system by the Director of Federal Grants for the reimbursement period and attached to the reimbursement request. While reimbursement requests were to be prepared by the Director of Federal Grants and reviewed by the Title I Director or Title I Budget Supervisor, no evidence of this review or oversight process was available. Of the four reimbursement requests selected for testing, three could not be verified against either the summary-level detail attached to the request or a detailed transaction listing. Because the amounts requested for reimbursement could not be traced to underlying records or to reports that accumulated or summarized the data, the accuracy and completeness of the reimbursement requests could not be verified. Final Expenditure Reports Final expenditure reports were expected to be prepared by the Director of Federal Grants using year-to-date expenditure data and reviewed by either the Director of Internal Audit or the Title I Budget Supervisor. However, no evidence was available to show that this review or oversight process took place. The lack of internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 29 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 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." Cause The School Corporation did not design or implement an effective internal control system to ensure the accuracy and compliance of reimbursement and final expenditure reporting processes. Specifically, the School Corporation did not have established procedures requiring the retention of detailed supporting documentation for reimbursement requests, and oversight responsibilities were not consistently carried out or evidenced over the reimbursement requests and final expenditure reports. Additionally, the employee responsible for preparing reimbursement requests during the audit period did not maintain the required documentation, and no secondary review process was in place to detect or correct these deficiencies. INDIANA STATE BOARD OF ACCOUNTS 30 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Because the School Corporation did not retain detailed documentation to support reimbursement requests or provide evidence of the required review of final expenditure reports, the audit team could not verify the accuracy, allowability, or completeness of expenditures charged to the grant. These gaps in documentation increased the audit time and administrative burden, as additional testing and follow-up were necessary to address missing records. As a result, the risk of misreporting, misallocation of federal funds, and potential violations of grant requirements were significantly heightened. Questioned Costs There were no questioned costs identified. Recommendation The School Corporation should establish and implement a formal internal control system to ensure accurate financial reporting and compliance with federal grant requirements. This system should include documented review procedures, clear segregation of duties, and consistent oversight of reimbursement requests and expenditure reports. All financial submissions should be supported by verifiable documentation and reconciled with internal records prior to submission. Additionally, the School Corporation should provide necessary support and resources to staff responsible for ensuring grant compliance. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-010 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U, 84.425C, 84.425W Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013, S425C200018, S425W210015 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-007. INDIANA STATE BOARD OF ACCOUNTS 37 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted one ESSER I report, one ESSER II report, and one ESSER III report, for a total of three reports. An effective internal control system was not in place at the School Corporation to ensure these reports were accurate. As such, the annual data reports were prepared and submitted to the IDOE without an oversight or review process to prevent or detect and correct errors. All three reports submitted during the audit period were not supported by the School Corporation's records. The following errors were identified: The ESSER I, Year 3 report, which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $1,526,046 in expenditures. However, actual expenditures for the applicable reporting period totaled $1,601,347. The ESSER II, Year 2 report, which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $10,293,210 in expenditures. However, actual expenditures for the applicable reporting period totaled $9,750,555. The ESSER III, Year 2 report, which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $15,939,167 in expenditures. However, actual expenditures for the applicable reporting period totaled $17,220,521. During the audit period, the School Corporation also received eight total reimbursements related to the COVID-19 - Education Stabilization Fund grant. The School Corporation received two GEER reimbursements, two ESSER I reimbursements, two ESSER II reimbursements, two ESSER III reimbursements, and 2 ARP HCY reimbursements. All reimbursement request forms were tested against the School Corporations records for accuracy. Of the eight reimbursements requested, six forms tested were not supported by the School Corporation's records. The following errors were identified: GEER reimbursement requests forms were overstated by $3,580 compared to the School Corporation's records. ESSER I reimbursement request forms were $860,284 overstated compared to the School Corporation's records. ESSER II reimbursement request forms were overstated by $221,808 compared to the School Corporation's records. ESSER III reimbursement request forms were understated by $220,484 compared to the School Corporation's records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 38 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following. . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause The School Corporation did not establish or implement a properly designed internal control system, including appropriate segregation of duties, to ensure the accuracy and reliability of financial data submitted to the IDOE. The absence of formal review procedures, oversight mechanisms, and reconciliation processes resulted in the submission of materially misstated annual data reports and reimbursement requests. Contributing factors included inadequate staff training on federal reporting requirements, the lack of documented financial reporting policies, and insufficient allocation of resources to monitor compliance with grant guidelines. Effect As a result, the annual data reports submitted to the IDOE via JotForm were materially misstated and lacked proper support from the School Corporation's financial records. Additionally, six out of eight reimbursement request forms tested during the audit period were either overstated or understated, reflecting inconsistent and inaccurate financial reporting tied to federal grant activity. These systemic errors represent significant noncompliance and undermine the reliability of reporting used for state and federal oversight. INDIANA STATE BOARD OF ACCOUNTS 39 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified Recommendation The School Corporation should strengthen its financial reporting processes related to federal grant activity by implementing a formal internal control system that ensures accuracy, consistency, and proper documentation. This includes reconciling financial records with data submitted through JotForm, establishing review procedures for reimbursement requests, and assigning qualified personnel to verify all reports prior to submission. Staff responsible for grant management and financial reporting should receive necessary support and resources regarding federal documentation standards and reporting requirements. The School Corporation should adopt standardized documentation policies and procedures across all departments to ensure compliance and oversight. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
REQUIREMENT REPORTING TYPE OF FINDING MATERIAL WEAKNESS FEDERAL PROGRAM 14.871 – SECTION 8 HOUSING CHOICE VOUCHERS CONDITION The Municipality did not submit or file the required FASS-PH financial report for the fiscal year ended June 30, 2023. At the completion of the audit, the report remained outstanding and had not been uploaded to the FASS-PH system, resulting in noncompliance with HUD’s reporting requirements. CRITERIA Entities administering the Section 8 Housing Choice Voucher Program (AL 14.871) must submit annual financial information to the U.S. Department of Housing and Urban Development (HUD) through the Financial Assessment Subsystem – Public Housing (FASS-PH). This requirement is established under: 2 CFR 200.327–200.328 (Uniform Guidance reporting requirements) HUD Uniform Financial Reporting Standards (UFRS) HUD Public Housing Assessment System (PHAS) – FASS-PH requirements Applicable HUD notices and guidance for FY 2023 These regulations require timely submission of complete and accurate financial data to allow HUD to evaluate the financial condition and compliance performance of the Municipality’s Housing Choice Voucher Program. CAUSE The failure to submit the FASS-PH report resulted from insufficient internal controls over the financial reporting process. Contributing factors included: Lack of a formal monitoring process to track HUD reporting deadlines Inadequate supervisory review of required submissions Limited staff knowledge of HUD’s UFRS and FASS-PH reporting procedures EFFECT Non-compliance may result in HUD administrative actions, negative impact on the municipality’s financial assessment score, delays or interruptions in federal funding and potential for increased oversight or monitoring by HUD. QUESTIONED COST None RECOMMENDATION The municipality should establish and document formal internal controls to ensure timely preparation and submission of the FASS-PH report. Assign responsibility to specific personnel and implement a compliance calendar for HUD reporting deadlines. Provide training to financial staff on HUD reporting requirements, UFRS, and the FASS-PH system. Implement a supervisory review process to verify completeness and accuracy before submission. Submit the outstanding FASS-PH report as soon as possible, if HUD still permits late filing.
Federal Agency: U. S. Department of Health and Human Services Cluster: Health Centers Clusters AL No.: 93.224 & 93.527 Program Title: Community Health Centers & Affordable Care Act (ACA) Grants for New and Expanded Services Under the Health Center Program Area: Reporting Repeat Finding from Prior Audit? Yes Finding Type: Material Weakness in Internal Control over Compliance Questioned Cost: $0.00 Criteria: Under Uniform Guidance (2 CFR §200.328), non-federal entities are required to submit complete, accurate, and timely financial and performance reports in accordance with federal award terms and conditions. Condition: The following SF-425, Federal Financial Reports for the reporting period ended March 31, 2023, were submitted after the required deadline of 90 days following the reporting period end date: AL No. Grant No. Reporting Date Date Submitted 93.224 21H8FCS41048C6 3/31/2023 7/27/2023 93.224 22H80CS31624 3/31/2023 8/3/2023 93.527 23H8GCS48480 11/30/2023 4/3/2024 Cause: Federal reporting requirements, including SF-425 and Uniform Data System (UDS) reporting, were not adequately monitored, documented, or retained. This condition was exacerbated by significant turnover in accounting and executive management and the absence of a formal turnover of federal reporting responsibilities and supporting records. Effect: Late submission of required federal financial reports and the absence of required UDS reporting documentation limit Kagman Community Health Center, Inc.’s ability to demonstrate compliance with federal reporting requirements. Recommendation: Kagman Community Health Center, Inc. should strengthen internal controls over federal reporting by: 1. Establishing procedures to track and monitor all federal financial and special reporting requirements, including SF-425 deadlines. 2. Implementing supervisory review procedures to verify the accuracy, completeness, and timeliness of federal reports prior to submission. 3. Establishing formal turnover and documentation procedures to ensure continuity of federal reporting responsibilities during personnel changes. Views of the Officials: Kagman Community Health Center, Inc.’s response is documented in the 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 § 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.
FINDING 2022-004 Subject: Staffing for Adequate Fire and Emergency Response (SAFER) - Cash Management Federal Agency: Department of Homeland Security Federal Program: Staffing for Adequate Fire and Emergency Response (SAFER) Assistance Listings Number: 97.083 Federal Award Number and Year (or Other Identifying Number): EMW-2019-FF-00944 Compliance Requirement: Cash Management Audit Findings: Material Weakness, Modified Opinion Condition and Context The Township submits request for reimbursements to the Federal Emergency Management Agency of the Department of Homeland Security. The reimbursement method of cash management requires the Township to retain supporting documentation that shows the costs for which reimbursement was requested were paid prior to the reimbursement date. The Township was awarded a SAFER grant to increase the number of firefighters and was approved for personnel and fringe benefits costs, which includes health insurance, for nine additional firefighters. The Township is self-insured and would make payments to third-party administrators and other benefit coordinators. The Township would pay a large dollar amount at the end of each year to its selfinsurance benefit coordinators for the next year's benefit, and then additional payments throughout the year as needed for employee's medical claim coverage. These payments were made from various Township funds and the Payroll Deductions fund. Additionally, the payroll deductions for health insurance, including those for employees paid from the grant, would accumulate in the Payroll Deductions fund, and be used for payments to the benefit coordinators as needed and the payment of the next year's required funding. The amount submitted for reimbursement for health insurance benefits were based upon a calculation. The Township did not have supporting documentation for the calculation of those benefits that were claimed. In addition, the health insurance benefits claimed for reimbursement were not paid out of the SAFER Grant Fund and were not at a transaction level in the ledger. The health insurance benefit submitted for reimbursement could not be tied to a specific payment; thus, we were unable to determine the Township's compliance for the health benefit reimbursements being incurred and paid prior to the Township's request for reimbursement. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302 states in part: "(a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the state's and the other 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. See also ? 200.450. (b) The financial management system of each non-Federal entity must provide for the following (see also ?? 200.334, 200.335, 200.336, and 200.337): (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number and year, name of the Federal agency, and name of the pass-through entity, if any. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. If a Federal awarding agency requires reporting on an accrual basis from a recipient that maintains its records on other than an accrual basis, the recipient must not be required to establish an accrual accounting system. This recipient may develop accrual data for its reports on the basis of an analysis of the documentation on hand. Similarly, a pass-through entity must not require a subrecipient to establish an accrual accounting system and must allow the subrecipient to develop accrual data for its reports on the basis of an analysis of the documentation on hand. (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. The non-Federal entity must adequately safeguard all assets and assure that they are used solely for authorized purposes. See ? 200.303. . . ." Cause A system of internal controls was not designed or implemented by management of the Township which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect management's expectation of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, health insurance benefits were requested for reimbursement without adequate supporting documentation that the amount was paid prior to the request. Noncompliance with the grant agreement and the cash management compliance requirement could result in the loss of future federal funds to the Township. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the Township establish a proper system of internal controls and develop policies and procedures to ensure expenses are paid prior to requesting reimbursement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2022-001 ? Finalize Budget Action Item Inaccuracies (Significant Deficiency) Identification of Federal Program: Name of Program: Shuttered Venue Operators Grant Program Assistance Listing Number: 59.075 Award Year: 2022 Pass-Through Entity: Direct Name of Federal Agency: U.S. Small Business Administration (?SBA?) Criteria: 2 CFR section 200.328 describes the financial reporting requirements for federal grant recipients. The terms and conditions of the award require the awardee to complete and submit the SF-425 report and a finalized budget (?Expense Report by Applicant?) using accurate data during the grant closeout process. The Finalized Budget Action Item allows grantees to update their budgets to reflect their finalized award and/or update allocations to allowable cost categories to align with actual or projected use of funds to date. Grantees do not need to request SBA approval to move costs between allowable cost categories. All grantees must complete the Finalize Budget Action Item. Condition: The following inaccuracies were noted within each allowable cost category reported on the Expense Report by Applicant, compared to actual expenses: Allowable Cost Category Expense Report by Applicant Actual expenses Difference 3. Equipment $ 40,000 $ - $ 40,000 5. Supplies 20,000 36,546 (16,546) 6. Contractual - 750,000 (750,000) 6b. Operating Leases 450,000 36,144 413,856 8d. Scheduled Debt Payments 550,000 - 550,000 8f. Other Business Expenses 60,000 14,299 45,701 8g. Administrative costs 20,000 8,032 11,968 8h. Insurance Payments 6,000 - 6,000 8i. Advertising 586,500 887,479 (300,979) Total $ 1,732,500 $ 1,732,500 $ - Cause: The errors in the Finalize Budget Action Item were due to inadequate review during the closeout process to ensure that the amounts reported agreed to actual grant expenditures. The management of the Association incorrectly believed that actual expenditures should exactly match the original budget which was initially approved. Effect: Improper preparation of the Finalize Budget Action Item resulted in the report being submitted while containing inaccurate amounts being reported within all allowable cost categories No questioned costs are reported within this finding, as the Association?s actual expenditures were greater than the federal award received, and all disbursements were for the purposes and objectives set forth in the terms and conditions of the federal award. Recommendation: The Association should review financial reports prior to submission and ensure that amounts agree to internal financial data, and are in compliance with the grant agreement. Views of Responsible Officials: Management of the Association concurs with the audit finding. The Association will enact procedures to ensure that grant reports are submitted with accurate financial information.
FINDING 2022-002 Condition: The Organization filed some of its SF-425 Federal Financial Reports with inaccurate expenditure amounts. The amounts did not agree with the Organization?s grant expense tracking system. The auditor discovered the inaccurate reports when testing the grant revenue for significant federal awards as part of the financial audit. The inaccurate reports were associated with at least two of eight federal awards spent during 2022 but were not associated with the major program that was tested. The inaccurate reports typically showed expenditures in an amount equal to the total award pro-rated equally on a quarterly basis over the award period, instead of actual expenditures. In some cases, this resulted in the SF-425 reporting more expenditures than actually incurred. Some of the dates were also inaccurate or did not get updated properly. Criteria: The Uniform Guidance (2 CFR section 200.328) addresses requirements regarding financial reporting. The Organization?s federal award contracts typically require the SF-425 report to be filed quarterly and that the report be true, complete, and accurate. Cause: The Organization inadvertently had some typographical errors in the report. There was also confusion regarding how to accurately complete the report. Effect: The Organization filed inaccurate SF-425 Federal Financial Reports for some of its federal awards. This did not directly affect the major program that was tested during the audit but is considered a significant deficiency in internal control over compliance, particularly compliance related to reporting, for federal awards. It is also considered to be noncompliance with federal award programs that were not tested as major programs. No adjustment to the financial statements was required. Recommendation: The Organization should reevaluate its procedures and controls regarding federal financial reporting, particularly the accuracy of the reporting, to ensure proper compliance. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding and plans to carry out the noted recommendation.
FINDING 2022-002 Condition: The Organization filed some of its SF-425 Federal Financial Reports with inaccurate expenditure amounts. The amounts did not agree with the Organization?s grant expense tracking system. The auditor discovered the inaccurate reports when testing the grant revenue for significant federal awards as part of the financial audit. The inaccurate reports were associated with at least two of eight federal awards spent during 2022 but were not associated with the major program that was tested. The inaccurate reports typically showed expenditures in an amount equal to the total award pro-rated equally on a quarterly basis over the award period, instead of actual expenditures. In some cases, this resulted in the SF-425 reporting more expenditures than actually incurred. Some of the dates were also inaccurate or did not get updated properly. Criteria: The Uniform Guidance (2 CFR section 200.328) addresses requirements regarding financial reporting. The Organization?s federal award contracts typically require the SF-425 report to be filed quarterly and that the report be true, complete, and accurate. Cause: The Organization inadvertently had some typographical errors in the report. There was also confusion regarding how to accurately complete the report. Effect: The Organization filed inaccurate SF-425 Federal Financial Reports for some of its federal awards. This did not directly affect the major program that was tested during the audit but is considered a significant deficiency in internal control over compliance, particularly compliance related to reporting, for federal awards. It is also considered to be noncompliance with federal award programs that were not tested as major programs. No adjustment to the financial statements was required. Recommendation: The Organization should reevaluate its procedures and controls regarding federal financial reporting, particularly the accuracy of the reporting, to ensure proper compliance. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding and plans to carry out the noted recommendation.
2022-001 Internal Control over Compliance and Compliance with the Reporting Compliance Requirement See Schedule of Findings and Questioned Costs for chart/table. Criteria or Specific Requirement: In accordance with ?200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. ?200.328, Monitoring and Reporting Program Performance, documents that the non-federal entity is responsible for oversight of the operations of the federal award supported activities. The non-federal entity must monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved. Monitoring by the non-federal entity must cover each program, function or activity. The non-federal entity must submit performance reports at the interval required by the federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent 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. In accordance with the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The prime awardee is required to file a Transparency Act sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. Condition: During BDO?s testing of the performance reporting requirements, BDO noted management continues to rely upon a manual process related to tracking and monitoring performance reporting. Programmatic Report Testing For one of six performance reports tested for major program AL# 93.067, a report was submitted after the due date without approval for late submission. Federal Funding Accountability and Transparency Act Reporting Testing We also performed testing over the Transparency Act reporting requirements outlined in the criteria section above. The OMB Compliance Supplement requires certain information be included in the finding when non-compliance exists. Of the 72 subaward original agreements and modifications totaling $10,993,519 (award amounts) for award 7200AA18C00014 that were tested, nine of the 72 reports with award amounts totaling $505,573 were not submitted timely. Of the four subaward original agreements and modifications totaling $731,250 (award amounts) for award NU2GGH002295 that were tested, one of the four reports with an award amount totaling $166,250 was not submitted timely. Questioned Costs: There are no questioned costs as the items described above are all related to late submission of reports. Context: This is a condition identified during BDO?s testing of performance reports and Transparency Act reports. Our sample for performance reporting was selected through a non-statistical sample. Our sample for Transparency Act reporting was selected based on a population of Transparency Act reports provided by management as well as through our subrecipient monitoring testing at the subrecipient level. We tested all Transparency Act report submissions in 2022 for the subrecipients selected for testing. Our sample for Transparency Act reporting was selected through non-statistical sampling. Cause: The quasi-manual performance reporting continues to challenge PSI given the number of awards under management and the number of reports required. PSI programmatic personnel have been unable to ensure the timely submission of reports because of this manual process. Effect: Failure to properly track all performance reporting requirements and Transparency Act reporting requirements impacts the Federal agency from obtaining performance information required to assess award performance on a macro level. Such non-compliance also increases the risk of loss of future awards if compliance with award terms are not met. Repeat Finding: This is a repeat finding from the prior year. This was reported as finding 2021-001 in the 2021 schedule of findings and questioned costs. Recommendation: In order to facilitate accurate and timely reporting and compliance with the terms and conditions of federal awards, BDO recommends management ensure all performance reporting requirements are maintained, updated, and available in a central location. BDO also recommends management implement a process by which approvals, submission considerations and supporting documentation for programmatic reports and Transparency Act reports is maintained in a centralized location. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and will work with project teams to review and confirm the accuracy of reporting deadlines. Refer to management?s corrective action plan for additional information.
Finding 2022-02: 15.631 Partners for Fish and Wildlife Criteria: 2 CFR 200.328 requires entities to comply with financial reporting as communicated in the federal award terms. Condition and Context: For the year ended December 31, 2022, Klamath Watershed Partnership?s financial reporting were reported on form SF-425 for the multiple federal awards under the Partners for Fish and Wildlife program. 4 reports were identified with inaccuracies. Cause: Klamath Watershed Partnership incidentally reported amounts on specific lines that weren?t aligned with the amounts supported through underlying records. Effect or Potential Effect: The reports filed reported erroneous amounts for multiple federal awards. Questioned Costs: None Context: The reports were prepared accurately in most of the SF-425 reports, but there were 4 reports that were not accurate. These 4 reports varied in the areas of the discrepancies. This suggests that the issue is not isolated or systemic, but a combination of both. Recommendation: Klamath Watershed Partnership should attach the report or other information used to prepare the reports for the use of the employee responsible for reviewing the report prior to filing. Also, management should amend the reports identified. Views of responsible officials and planned corrective actions: Management agrees with the finding and will perform a review with supporting information in future filings. Also, management will amend the identified reports.
FINDING 2022-004 ? CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS - REPORTING Federal Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN Number: 21.027) Federal Agency: Department of Treasury Federal Award Number (or Other Identifying Number): N/A Pass-Through Entity: State Budget Agency Audit Finding: 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: During testing, we noted the County did not have a review control in place to ensure accuracy and completeness of the quarterly reporting requirements. Questioned Cost: None.Context: There was no documented review by someone other than the preparers of the Project and Expenditure Report to ensure the information submitted was accurate and complete. The reports are prepared and submitted by the County Attorney without secondary review. As a result, one of the quarterly reports selected for testing, out of a sample of two reports, was overstated by $247,770 in one period due to improper inclusion of an expenditure made in a subsequent month. This timing error was corrected on the next quarterly support and similar errors were not identified in subsequent quarters. Final reporting of total expenditures was accurate. Effect: The failure to establish an effective internal control system placed the County at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the program. Cause: Management had not developed a system of internal control that would have ensured compliance with the grant agreement and the compliance requirements listed above for the full period under audit. Repeat Finding: No. Recommendation: We recommended that the County's management establish a system of internal control to ensure compliance with the grant agreement and the compliance requirements listed above. We recommend an individual other than the County Attorney perform a documented review of the report prior to submission. Views of Responsible Officials: Management concurs with this finding. See the corrective action plan.