FINDING 2022-001 Subject: Formula Grants for Rural Areas and Tribal Transit Program - Reporting Federal Agency: Department of Transportation Federal Program: Formula Grants for Rural Areas and Tribal Transit Program Assistance Listings Number: 20.509 Federal Award Numbers and Years (or Other Identifying Numbers): 1804006O, 1803906O Pass-Through Entity: Indiana Department of Transportation Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The City had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. Recipients of the Formula Grants for Rural Areas and Tribal Transit Program are required to submit claim vouchers quarterly to the Indiana Department of Transportation (INDOT). Each quarterly reimbursement request is to reflect the total expenditures for the quarter then ended. The City submitted a total of five claim vouchers during the audit period; however, one of the claim vouchers was not properly prepared. The fourth quarter claim voucher for 2021, covering the period of October 2021 to December 2021, submitted to the INDOT by the City, incorrectly included the expenditures for September 2021 instead of the expenditures for October 2021. This caused the September 2021 expenditures to be reimbursed for a second time, and the October 2021 expenditures to not be reimbursed. The September 2021 expenditure amount was $72,824; however, the October 2021 expenditure amount was $182,909. The October 2021 expenditures have not been requested for reimbursement to date. The lack of internal controls and noncompliance was isolated to the fourth quarter claim voucher for 2021. 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 200.328 states: "Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMBapproved 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." Cause A proper system of internal controls over the quarterly expenditure report was not designed by management of the City to ensure the correct expenditures were requested for reimbursement. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the City'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, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. 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 City. In addition, not requesting reimbursement for the correct amount led to the City not being reimbursed for all applicable expenditures. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the City design and implement a proper system of internal controls that would provide a segregation of duties for the preparation and review of federal reports to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
"Finding 2022-007 Reporting – Significant Deficiency. Criteria: 2 CFR section 200.328 states that information must be collected with the frequency required by the terms and conditions of the Federal award. The Organization’s Project Service Agreement indicates that invoices for monthly financial reporting are due to the pass-through entity by the tenth business day of the month for the previous calendar month, except for the last invoice of the 2022 calendar year which was due on January 10, 2023. Questioned Costs: Not applicable. Repeat Finding: Not applicable as the Organization is a first time auditee. Recommendation: We recommend that the Organization develop more effective policies and controls to ensure that the reports are remitted within the time frame specified in the agreements. Views of Responsible Official: See Corrective Action Plan. Condition: In our sample of four monthly invoices, all four were submitted after the deadline prescribed in the agreement. Cause: The Organization has no controls in place to ensure that reports are remitted on a timely basis. Effect: The effect is minimal since the pass-through entity still accepted the reports and reimbursed the Organization for the majority of the requested funds."
#2022-009 - Major Federal Award Finding - Reporting Nature of Finding: Compliance Finding - Reporting and Material Weakness in Internal Controls Over Compliance Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing that no review procedures are in place surrounding these reports. Cause/Context: Controls were not in place to ensure accurate reporting. Only one individual was involved in the reporting process. Of the two reports tested, one Federal Status Report included an expenditure reported in an inaccurate budget category. Payroll tax costs were divided between the Fringe Benefits/Payroll tax budget line and the Other Expenses line, with a total of $1,554 reported in the incorrect budget category. Additionally, the client failed to identify that submission of a single audit was an applicable reporting requirement for the December 31, 2022 year, resulting in a late single audit filing. Effect: The lack of controls resulted in inaccurate, late, and failed reporting compliance. Recommendation: We recommend that a full-range of controls related to reporting, including federal program reporting be implemented. The Organization should devote the resources necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval should be documented and that documentation be maintained. Views of Responsible Officials and Planned Corrective Actions: MARR will retain a CPA consultant to implement a full-range of controls relating to reporting, including federal program reporting. MARR will take such steps as necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval will be documented in such documentation to be maintained.
#2022-009 - Major Federal Award Finding - Reporting Nature of Finding: Compliance Finding - Reporting and Material Weakness in Internal Controls Over Compliance Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing that no review procedures are in place surrounding these reports. Cause/Context: Controls were not in place to ensure accurate reporting. Only one individual was involved in the reporting process. Of the two reports tested, one Federal Status Report included an expenditure reported in an inaccurate budget category. Payroll tax costs were divided between the Fringe Benefits/Payroll tax budget line and the Other Expenses line, with a total of $1,554 reported in the incorrect budget category. Additionally, the client failed to identify that submission of a single audit was an applicable reporting requirement for the December 31, 2022 year, resulting in a late single audit filing. Effect: The lack of controls resulted in inaccurate, late, and failed reporting compliance. Recommendation: We recommend that a full-range of controls related to reporting, including federal program reporting be implemented. The Organization should devote the resources necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval should be documented and that documentation be maintained. Views of Responsible Officials and Planned Corrective Actions: MARR will retain a CPA consultant to implement a full-range of controls relating to reporting, including federal program reporting. MARR will take such steps as necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval will be documented in such documentation to be maintained.
2022-001: Late Filing of the Data Collection Form All Federal programs included in the Schedule of Expenditures of Federal Awards Compliance Findings: Other (P) Condition: Range Mental Health Center, Inc. and Subsidiary 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 nonfederal 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: Range Mental Health Center, Inc. and Subsidiary did not submit its year ended December 31, 2021 audit reporting package to the Federal Audit Clearinghouse until April 4, 2023, and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Range Mental Health Center, Inc. and Subsidiary 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 outsosurced its CFO function to improve the timeliness of financial activities. Additional details can be found in the Organization’s Corrective Action Plan.
2022-001: Late Filing of the Data Collection Form All Federal programs included in the Schedule of Expenditures of Federal Awards Compliance Findings: Other (P) Condition: Range Mental Health Center, Inc. and Subsidiary 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 nonfederal 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: Range Mental Health Center, Inc. and Subsidiary did not submit its year ended December 31, 2021 audit reporting package to the Federal Audit Clearinghouse until April 4, 2023, and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Range Mental Health Center, Inc. and Subsidiary 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 outsosurced its CFO function to improve the timeliness of financial activities. Additional details can be found in the Organization’s Corrective Action Plan.
2022-001: Late Filing of the Data Collection Form All Federal programs included in the Schedule of Expenditures of Federal Awards Compliance Findings: Other (P) Condition: Range Mental Health Center, Inc. and Subsidiary 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 nonfederal 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: Range Mental Health Center, Inc. and Subsidiary did not submit its year ended December 31, 2021 audit reporting package to the Federal Audit Clearinghouse until April 4, 2023, and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Range Mental Health Center, Inc. and Subsidiary 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 outsosurced its CFO function to improve the timeliness of financial activities. Additional details can be found in the Organization’s Corrective Action Plan.
2022-001: Late Filing of the Data Collection Form All Federal programs included in the Schedule of Expenditures of Federal Awards Compliance Findings: Other (P) Condition: Range Mental Health Center, Inc. and Subsidiary 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 nonfederal 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: Range Mental Health Center, Inc. and Subsidiary did not submit its year ended December 31, 2021 audit reporting package to the Federal Audit Clearinghouse until April 4, 2023, and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Range Mental Health Center, Inc. and Subsidiary 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 outsosurced its CFO function to improve the timeliness of financial activities. Additional details can be found in the Organization’s Corrective Action Plan.
2022-001: Late Filing of the Data Collection Form All Federal programs included in the Schedule of Expenditures of Federal Awards Compliance Findings: Other (P) Condition: Range Mental Health Center, Inc. and Subsidiary 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 nonfederal 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: Range Mental Health Center, Inc. and Subsidiary did not submit its year ended December 31, 2021 audit reporting package to the Federal Audit Clearinghouse until April 4, 2023, and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Range Mental Health Center, Inc. and Subsidiary 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 outsosurced its CFO function to improve the timeliness of financial activities. Additional details can be found in the Organization’s Corrective Action Plan.
2022-001: Late Filing of the Data Collection Form All Federal programs included in the Schedule of Expenditures of Federal Awards Compliance Findings: Other (P) Condition: Range Mental Health Center, Inc. and Subsidiary 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 nonfederal 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: Range Mental Health Center, Inc. and Subsidiary did not submit its year ended December 31, 2021 audit reporting package to the Federal Audit Clearinghouse until April 4, 2023, and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Range Mental Health Center, Inc. and Subsidiary 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 outsosurced its CFO function to improve the timeliness of financial activities. Additional details can be found in the Organization’s Corrective Action Plan.
2022-001: Late Filing of the Data Collection Form All Federal programs included in the Schedule of Expenditures of Federal Awards Compliance Findings: Other (P) Condition: Range Mental Health Center, Inc. and Subsidiary 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 nonfederal 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: Range Mental Health Center, Inc. and Subsidiary did not submit its year ended December 31, 2021 audit reporting package to the Federal Audit Clearinghouse until April 4, 2023, and did not meet the nine month reporting requirement for the year ended December 31, 2022. Recommendation: We recommend Range Mental Health Center, Inc. and Subsidiary 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 outsosurced its CFO function to improve the timeliness of financial activities. Additional details can be found in the Organization’s Corrective Action Plan.
Criteria: The Uniform Guidance Compliance Supplement (2 CFR 200.328) and Federal Register requires recipients of the Coronavirus State and Local Fiscal Recovery Funds (ARPA) to submit periodic federal financial and performance reports. Condition: Upon request, the periodic financial reports were not provided for review. The County indicated that they did not file any of the required reports.
Reporting Finding Number: 2022-005 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2022 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Reporting Pass-Through Entity: N/A Repeat Finding from Prior Audit? No Noncompliance and Material Weakness 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.328 which provides that, 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. 24 CFR § 5.801 (d)(1) provides that unaudited financial statements will be required 60 days after the PHA's fiscal year end, and audited financial statements will then be required no later than 9 months after the PHA's fiscal year end, in accordance with the Single Audit Act and 2 CFR part 200, subpart F. In addition, 24 CFR § 5.801 (b)(1) provides that entities to which this subpart is applicable must provide to HUD such financial information as required by HUD prepared in accordance with Generally Accepted Accounting Principles (GAAP). The Authority submitted its audited submission for the year ended December 31, 2021 in the Financial Assessment Sub-system (FASS-PH) on January 30, 2024. This submission was rejected and resubmitted on March 21, 2024. The Authority had received a sixty-day extension until November 30, 2022. This submission was not within the required timeframes or extension. The delays in submissions were due to investigations into fraudulent transactions by the former Executive Director. The failure to timely submit the required financial information reduces the U.S. Department of Housing and Urban Development’s ability to monitor subrecipients. Although the annual financial statements were prepared in accordance with GAAP, a required Statement of Cash Flows was not included. The Authority should continue working with their compiler and auditors to rectify the accounting issues resulting from the actions of the former Executive Director. Once that is completed, the Authority should timely remit the required reports and submit a complete annual financial report prepared in accordance with GAAP.
Reporting Finding Number: 2022-005 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2022 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Reporting Pass-Through Entity: N/A Repeat Finding from Prior Audit? No Noncompliance and Material Weakness 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.328 which provides that, 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. 24 CFR § 5.801 (d)(1) provides that unaudited financial statements will be required 60 days after the PHA's fiscal year end, and audited financial statements will then be required no later than 9 months after the PHA's fiscal year end, in accordance with the Single Audit Act and 2 CFR part 200, subpart F. In addition, 24 CFR § 5.801 (b)(1) provides that entities to which this subpart is applicable must provide to HUD such financial information as required by HUD prepared in accordance with Generally Accepted Accounting Principles (GAAP). The Authority submitted its audited submission for the year ended December 31, 2021 in the Financial Assessment Sub-system (FASS-PH) on January 30, 2024. This submission was rejected and resubmitted on March 21, 2024. The Authority had received a sixty-day extension until November 30, 2022. This submission was not within the required timeframes or extension. The delays in submissions were due to investigations into fraudulent transactions by the former Executive Director. The failure to timely submit the required financial information reduces the U.S. Department of Housing and Urban Development’s ability to monitor subrecipients. Although the annual financial statements were prepared in accordance with GAAP, a required Statement of Cash Flows was not included. The Authority should continue working with their compiler and auditors to rectify the accounting issues resulting from the actions of the former Executive Director. Once that is completed, the Authority should timely remit the required reports and submit a complete annual financial report prepared in accordance with GAAP.
Condition: The organization could not provide copies of periodic financial and performance reports submitted to the federal awarding agency or pass‐through entity for the ERA program. Criteria: 2 CFR 200.328 requires non‐federal entities to submit accurate and timely financial and performance reports to the awarding agency. Cause: The absence of policies and procedures for maintaining these records resulted in their unavailability during the audit. Effect: Failure to maintain these reports limits the ability to substantiate compliance with the reporting requirements. Recommendation: Develop and implement procedures to ensure financial and performance reports are prepared, reviewed, and retained. Questioned Costs: None Management’s Response: Management acknowledges the need to address and enhance this area finding. We are committed to implementing new procedures for recording and tracking program income, including documenting its source, amount, and application. These procedures will be put in place within three months, with oversight provided by senior management to ensure proper compliance and effective implementation.
Federal Agency: United States Department of Commerce Federal Program Name: Office for Coastal Management Assistance Listing Number: 11.473 Federal Award Identification Year: 2020 Pass-Through Agency: National Fish and Wildlife Grant Agreement Award Period: 9/1/20-08/31/23 Type of Finding: Other Matters - Significant Deficiency in Internal Control Criteria: 2 CFR 200.328 - Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB approved, governmentwide data elements available from the OMB designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. 2 CFR 200.329(c)(1) -Requirements state that the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or passthrough entity to best inform improvements in program outcomes and productivity. Condition: For one of the two reports selected for testing, CFSC did not submit the reports to the National Fish and Wildlife Foundation by the required date. Context: A nonstatistical sample of 2 out of 4 required reports were selected for testing for the Office for Coastal Management program. The condition noted above was identified during our procedures over the CFSC’s reporting requirements. Effect: CFSC did not submit required reports in a timely manner, increasing the risk of noncompliance. Cause: CFSC’s procedures did not consistently ensure that the required reports were submitted on a timely basis. Repeat Finding: The finding is a repeat finding. Recommendation: We recommend that management modify and strengthen its current policies and procedures to ensure that all required reports are submitted on a timely basis to the appropriate Federal Agency or Pass-Through Entity. Management’s Views: See separate corrective action plan.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass- through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreement for McConnelsville NRG Sewer Facility Improvements (B-F-19-1CA-1) state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), one out of one (one hundred percent) of Status Reports were submitted seven months late. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass- through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreement for McConnelsville NRG Sewer Facility Improvements (B-F-19-1CA-1) state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), one out of one (one hundred percent) of Status Reports were submitted seven months late. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass- through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreement for McConnelsville NRG Sewer Facility Improvements (B-F-19-1CA-1) state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), one out of one (one hundred percent) of Status Reports were submitted seven months late. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass- through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreement for McConnelsville NRG Sewer Facility Improvements (B-F-19-1CA-1) state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), one out of one (one hundred percent) of Status Reports were submitted seven months late. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
FINDING 2022-003 Information on the federal program: Subject: Water and Waste Disposal Systems for Rural Communities – Reporting Federal Agency: U.S. Department of Agriculture Assistance Listing Number: 10.760 Federal Award Number: 92-02 92-03 Pass-Through Entity: N/A Compliance Requirements: Reporting Audit Findings: Significant Deficiency Criteria: 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: The City did not have proper controls in place to ensure that the annual report was accurately filled out and agreed to underlying detail. Cause: There were not sufficient internal controls in place to ensure the accuracy of the annual report prior to its submission. Effect: The failure to establish an effective internal control system placed the City at risk of noncompliance with the grant agreement and the Reporting compliance requirements. Questioned Costs: There were no questioned costs identified. Context: Variances to key line items were noted when comparing the Form RD442-2 and Form RD442-3 to supporting documents. Identification as a repeat finding, if applicable: No Recommendation: We recommend someone other than the preparer thoroughly review and document the review of the report prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Compliance Requirement: L Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late. Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period). Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance. Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance. Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: L Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late. Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period). Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance. Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance. Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: L Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late. Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period). Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance. Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance. Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: L Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late. Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period). Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance. Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance. Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: L Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late. Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period). Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance. Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance. Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: L Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late. Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period). Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance. Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance. Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Compliance Requirement: L Condition: Annual Federal Financial Reports (FFR) and Program Performance Reports (PPR) were not completed and submitted to the federal agency on time as required by the terms and conditions of the award. 8 of 12 reports reviewed were submitted late. Criteria: Federal grant agreements and 2 CFR Part §200.328, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require recipients to submit FFR and PPR within specified deadlines (typically within 90 days of the award period). Cause and effect: Staffing resource constraints led to noncompliance with terms and conditions of the federal awards and the Uniform Guidance. Recommendation: I recommend that management review its current processes and procedures to ensure reports are submitted timely, reviewed, and ensure evidence is retained to support the compilation, review, and submission of the reports and ensure compliance with Uniform Guidance. Views of Responsible Officials: All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.
Finding 2022-002: Lack of documentation of review and approval - Material Weakness Program name: Office for Coastal Management Assistance Listing: 11.473 Federal award Identification number: 20 NFWF 339630 Federal award year: 9/1/2020 - 8/31/2023 Federal awarding agency: U.S. Department of Commerce Criteria - In accordance with 2 CFR 200.303, recipients and subrecipients must establish, document and maintain effective internal control over Federal awards. These controls should be in compliance with Federal statutes, regulations, and the terms and conditions of the award, and should align with standards such as the “Standards for Internal Control in the Federal Government” (Green Book) or the COSO framework. This includes controls over: * Payroll: Ensuring labor charges are accurate, allowable, and properly approved (2 CFR 200.430). * Expenses: Ensuring proper documentation and approval. (2 CFR 200.400(d) ) * Reporting: Ensuring financial reports are accurate, complete, and reviewed prior to submission (2 CFR 200.328). Condition - The Organization has limited written processes of certain transaction classes. There was a pervasive lack of documentation of approval over transactions, including payroll, expenses, and reporting. Cause - The Organization did not maintain or consistently apply documentation protocols for internal control reviews. Formal documentation practices were not in place during the audit period. Effect - Lack of documentation as evidence that controls over compliance were being performed. Documentation should be maintained as evidence that sufficient control activities are in place and would effectively prevent or detect and correct noncompliance. Controls must be followed for every transaction and documentation of the control being performed must be maintained. Questioned costs - None identified. Perspective - The deficiency was pervasive across multiple compliance areas and was not isolated to a specific transaction or department. The scope indicates a systemic control weakness during the audit period. Identification of Repeat Findings - This is not a repeat finding. Recommendation - We recommend that the Organization ensure updated policies and procedures are implemented and consistently applied. This includes: * Documented review and approval of all transactions related to payroll, expenses, and reporting. * Maintenance of written evidence supporting such reviews. * Regular training and internal monitoring to ensure control procedures are consistently followed. Management response - See corrective action plan
2022-108 Lack of Documentation Related to Reporting (prior two years 2021-108 and 2020-104) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H80CS06452 (2022) and COVID-19 ARP H8FCS40324 (2021) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to include only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization.
2022-108 Lack of Documentation Related to Reporting (prior two years 2021-108 and 2020-104) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H80CS06452 (2022) and COVID-19 ARP H8FCS40324 (2021) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to include only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization.
2022-108 Lack of Documentation Related to Reporting (prior two years 2021-108 and 2020-104) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H80CS06452 (2022) and COVID-19 ARP H8FCS40324 (2021) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to include only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization.
2022-108 Lack of Documentation Related to Reporting (prior two years 2021-108 and 2020-104) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H80CS06452 (2022) and COVID-19 ARP H8FCS40324 (2021) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to include only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization.
2022-108 Lack of Documentation Related to Reporting (prior two years 2021-108 and 2020-104) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H80CS06452 (2022) and COVID-19 ARP H8FCS40324 (2021) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to include only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization.
2022-108 Lack of Documentation Related to Reporting (prior two years 2021-108 and 2020-104) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H80CS06452 (2022) and COVID-19 ARP H8FCS40324 (2021) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to include only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization.
2022-108 Lack of Documentation Related to Reporting (prior two years 2021-108 and 2020-104) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H80CS06452 (2022) and COVID-19 ARP H8FCS40324 (2021) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to include only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization.
2022-108 Lack of Documentation Related to Reporting (prior two years 2021-108 and 2020-104) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H80CS06452 (2022) and COVID-19 ARP H8FCS40324 (2021) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to include only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization.
Criteria or Specific Requirement: 2 CFR 200.328 and 31 CFR section 35.4(c) requires submission of quarterly and annual project and expenditure reports which are due to the Department of Treasury 30 days after the end of each quarter and April 30th, of the year proceeding, respectively. The project and expenditure report contains specific instructions on how to complete the report. Within the project and expenditure report, ‘Expenditure Categories’ is a critical component to be completed by reporting “obligations” and “expenditures” on each project. As defined in the report, “obligation” is an order placed (such as a contract) and similar transactions that require payment; “expenditure” is when the service has been rendered or the good has been delivered to the entity, and payment is due. Condition: Upon review and testing of the quarterly reports as submitted to the Department of Treasury, it was noted that amounts reported as expenditures for certain projects included amounts that were obligated but not yet incurred (service was not yet rendered or the good was not yet received) until a subsequent quarter. The expenditures as reported were allowable expenditures, but the timing of the expenditures was reported in the incorrect period. In addition, upon testing the expenditures as reported in the unadjusted schedule of expenditures of federal awards (the “schedule”), it was noted that $549,431 was improperly included as expenditures belonging to the fiscal year ended September 30, 2022. The expenditures identified were prematurely recorded in the general ledger since the equipment was not received until after year-end. The City’s schedule of expenditures of federal awards for the fiscal year ended September 30, 2022 required a correction to remove those amounts from the schedule and to add those amounts to the subsequent fiscal year’s schedule. Cause: The Grants Administrator’s lack of understanding of the proper manner in which the obligations and expenditures are required to be reported in the quarterly reports resulted in expenditure amounts being reported in the incorrect quarters. The City’s year-end procedures did not identify certain necessary adjustments in a timely manner in order to remove capital outlay expenditures that were incorrectly recorded during the fiscal year ended September 30, 2022 and were incorrectly included in the unadjusted schedule of expenditures of federal awards. The Grants Administrator utilized the amounts recorded as expenditures in the accounting system to prepare the quarterly reports. Expenditures should be recorded in the City’s general ledger utilizing the date services are rendered and/or goods are received. Proper monthly review of the expenditure accounts should have led to identifying expenditures that were recorded but not yet incurred. Effect or Potential Effect: The two conditions listed above resulted in differences between expenditure amounts as correctly adjusted and reported in the schedule of expenditures of federal awards, versus expenditure amounts as reported and submitted to the Department of Treasury in the quarterly reports. Future reports may be incorrectly completed if obligation amounts and expenditure amounts are not following the criteria to properly enter amounts in the quarterly reports. Questioned Costs: None. Context: During compliance testing of the reporting compliance requirement, it was noted that the total expenditures included in the schedule of expenditures of federal awards for the fiscal year ended September 30, 2022 did not agree to the total expenditures reported in the quarterly expenditure reports as submitted to the Department of Treasury for the same period. During testing of disbursements as included in the schedule of expenditures of federal awards for the major Federal program, and during internal control and compliance testing, from a total of forty-five disbursements it was noted there were four disbursements, amounting to a total of $549,431, recorded within accounts payable as capital outlay expenditures which were improperly recorded in the fiscal year ended September 30, 2022 and improperly included in the schedule of expenditures of federal awards. As evidenced by the invoice date and ship date within the invoices, the equipment was not shipped, and the equipment was not received by the City, until after year-end. The expenditures should be recorded and reported in the fiscal year ended September 30, 2023. Adjustments were made accordingly for proper recording, reporting, and presentation in the financial statements and schedule of expenditures of federal awards. Recommendation: Management should ensure year-end closing procedures are completed in a timely manner and are sufficient to assure accounts and financial statements are prepared in accordance with GAAP. If properly prepared and recorded, the subledgers for expenditures by federal awards will be generated with accurate expenditure amounts for the fiscal year. Management should assess the risk associated with this condition and identify any additional processes that can be incorporated into their existing controls to improve the deficiency; such as, minimizing the likelihood of year-end material audit adjustments through review of transactions and balances for general propriety and accuracy within one month after year-end. Follow-up and inquiries can be made timely for any transactions for which proper recording is unclear to management, if any. The Grants Administrator should maintain an up-to-date listing of expenditures by award (for all federal, state, and local awards) and should communicate with the Finance Department on a monthly basis to review the listing and determine the proper period in which the expenditures should be recorded and presented. The Grants Administrator and Finance Department should prepare a reconciliation of the expenditures as reported in the schedule of expenditures of federal awards for the major Federal program for the fiscal year ended September 30, 2022, as well as expenditures incurred from October 1, 2022 through today, and compare to the expenditures as reported in all quarterly reports through September 30, 2023. An analysis should be completed to determine the differences between the expenditures incurred by quarter versus expenditures as reported by quarter, and to determine the differences in total between expenditures incurred and expenditures reported in the quarterly and annual project and expenditure reports. The Grants Administrator should then review the Department of Treasury’s Project and Expenditure Report User Guide of State and Local Fiscal Recovery Funds, and/or contact the grantor, to determine if reports as previously submitted should be corrected for the timing difference, or to determine what the correct course of action should be.
Finding Number: 2022-005 Prior Year Finding Number: 2021-005 Compliance Requirement: Reporting Program: U.S. Department of the Treasury COVID-19 ? Emergency Rental Assistance (ERA) Program ALN: 21.023 Award #: N/A Award Year: 12/27/2020 ? 09/30/2025 Government Department/Agency: Department of Human Services Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.328 Financial Reporting: ?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.? The 2022 Compliance Supplement outlines the Special Reports required under the Emergency Rental Assistances program, and the key data elements, and the submission requirements. The Reporting Guidance is located on the Treasury?s website for the ERA program. Monthly Special Reports were required to be submitted on a monthly basis, beginning in April 2021 for ERA1 and June 2021 for ERA2, generally by the 15th of the following month unless otherwise specified within the Reporting Guidance. As outlined in the 2022 Compliance Supplement, the key data elements for the monthly reports included (1) the total number of participant households that received ERA assistance of any kind and (2) the total amount of ERA funds expended by the ERA grantee to or for participating households on behalf of eligible households. The program also requires ERA recipients to certify the reports submitted. As outlined in the 2022 Compliance Supplement, the key data elements for the quarterly reports included (1) the cumulative amount obligated by the grantee; and (2) the cumulative amount expended by the grantee. The program also requires ERA recipients to certify the reports submitted. Condition ? We noted the following for one of nine quarterly and monthly reports tested: ? For one quarterly report (the ERA1 Quarter 1 2022 Report), the key data elements (1) the cumulative amount obligated by the grantee; and (2) the cumulative amount expended by the grantee were not included in the quarterly report. Questioned Costs ? None. Context ? This is a condition identified per review of the Department of Human Services? compliance with specified requirements using a statistically valid sample. Effect ? Without proper internal controls and policies and procedures in place, the required financial and special reports are either not submitted or not submitted with accurate information. Cause ? Per discussion with management, it was noted that at the time the report was submitted they didn?t have access to key data elements to be input into the quarterly report. However, BDO could not verify that this was the case as there was no documentation around the same. Management did not establish controls to make sure that all the required information as noted in the compliance supplement was submitted to the Treasury Department. Recommendation ? We recommend that the Department of Human Services fully implement its current corrective action plan to deploy policies and procedures and controls to ensure reports are submitted with accurate information. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The Department of Human Services (DHS) concurs with the finding that we could not substantiate that cumulative expenditure and obligation data were included in the ERA1 Quarter 1 2022 Report, which was submitted on April 15, 2022 in the U.S. Department of the Treasury?s COVID-19 Relief Hub reporting portal. DHS believes that updates in the reporting format and fields caused this issue. U.S. Treasury Reporting staff has confirmed that when new fields are added or changed to reports within the reporting portal, these changes override prior submitted reports. In response to a similar finding for the fiscal year 2021 ERA single audit where original submission data was overridden by formatting updates, DHS began saving screen shots of reported data within Treasury?s reporting portal. This practice began in June 2022 and will continue for the duration of the ERA program, through ERA2 closeout reporting. This will ensure that even if Treasury reporting portal functionality changes in the future, there is clear supporting documentation of the information submitted. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-008 Prior Year Finding Number: 2021-010 Compliance Requirement: Reporting Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ALN #: 84.425E Award #: P425E201913 - 20B Award Year: 04/24/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Institutional Aid Portion ALN: 84.425F Award #: P425F202580 - 20B Award Year: 05/07/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Historically Black Colleges and Universities (HBCUs) ALN: 84.425J Award #: P425J200098 - 20C Award Year: 05/01/2020 ? 06/30/2023 Government Department/Agency: University of the District of Columbia Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, Education Department exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition ? During our testing of the quarterly public reporting requirements for HEERF Student Aid Portion and HEERF Institutional Portion, we noted the following: ? For three (3) out of six (6) reports, University of the District of Columbia (UDC) was not able to provide evidence of the timely posting of the quarterly public reports to the UDC website because the webmaster?s web posting audit log, which expires after 60 days, had not been retained by UDC. ? For three (3) out of six (6) reports, UDC was not able to provide evidence that the quarterly public reports were reviewed prior to posting to the UDC website because the evidence had not been retained by UDC. UDC implemented its corrective action plan on June 30, 2022, and the exceptions identified above relate to reporting transactions made prior to the above-mentioned implementation date. We also examined one report made post the above-mentioned implementation date and we noted that UDC had kept all evidence of review of the report and the evidence of the report being published in the UDC website. Questioned Costs ? None. Context ? This is a condition identified per review of UDC?s compliance with specified reporting requirements related to the program using a statistically valid sample. Effect ? Without adequate controls in place to ensure that reports are posted timely and proof that the reports were reviewed leads to noncompliance of the reporting requirements under the program. Cause ? UDC does not have adequate controls in place to ensure that documents are maintained related to the review and the timely posting of reports to the UDC website. Recommendation ? We recommend for UDC to continue to maintain documentation of the timely submission of reports and proof of review of reports as required to ensure compliance with reporting requirements. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? UDC OCFO agrees with the conditions and recommendations of this finding. As noted in the condition above, UDC implemented corrective action to remediate the conditions and recommendations reported in the prior year when findings were issued. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-008 Prior Year Finding Number: 2021-010 Compliance Requirement: Reporting Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ALN #: 84.425E Award #: P425E201913 - 20B Award Year: 04/24/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Institutional Aid Portion ALN: 84.425F Award #: P425F202580 - 20B Award Year: 05/07/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Historically Black Colleges and Universities (HBCUs) ALN: 84.425J Award #: P425J200098 - 20C Award Year: 05/01/2020 ? 06/30/2023 Government Department/Agency: University of the District of Columbia Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, Education Department exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition ? During our testing of the quarterly public reporting requirements for HEERF Student Aid Portion and HEERF Institutional Portion, we noted the following: ? For three (3) out of six (6) reports, University of the District of Columbia (UDC) was not able to provide evidence of the timely posting of the quarterly public reports to the UDC website because the webmaster?s web posting audit log, which expires after 60 days, had not been retained by UDC. ? For three (3) out of six (6) reports, UDC was not able to provide evidence that the quarterly public reports were reviewed prior to posting to the UDC website because the evidence had not been retained by UDC. UDC implemented its corrective action plan on June 30, 2022, and the exceptions identified above relate to reporting transactions made prior to the above-mentioned implementation date. We also examined one report made post the above-mentioned implementation date and we noted that UDC had kept all evidence of review of the report and the evidence of the report being published in the UDC website. Questioned Costs ? None. Context ? This is a condition identified per review of UDC?s compliance with specified reporting requirements related to the program using a statistically valid sample. Effect ? Without adequate controls in place to ensure that reports are posted timely and proof that the reports were reviewed leads to noncompliance of the reporting requirements under the program. Cause ? UDC does not have adequate controls in place to ensure that documents are maintained related to the review and the timely posting of reports to the UDC website. Recommendation ? We recommend for UDC to continue to maintain documentation of the timely submission of reports and proof of review of reports as required to ensure compliance with reporting requirements. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? UDC OCFO agrees with the conditions and recommendations of this finding. As noted in the condition above, UDC implemented corrective action to remediate the conditions and recommendations reported in the prior year when findings were issued. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-008 Prior Year Finding Number: 2021-010 Compliance Requirement: Reporting Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ALN #: 84.425E Award #: P425E201913 - 20B Award Year: 04/24/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Institutional Aid Portion ALN: 84.425F Award #: P425F202580 - 20B Award Year: 05/07/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Historically Black Colleges and Universities (HBCUs) ALN: 84.425J Award #: P425J200098 - 20C Award Year: 05/01/2020 ? 06/30/2023 Government Department/Agency: University of the District of Columbia Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, Education Department exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition ? During our testing of the quarterly public reporting requirements for HEERF Student Aid Portion and HEERF Institutional Portion, we noted the following: ? For three (3) out of six (6) reports, University of the District of Columbia (UDC) was not able to provide evidence of the timely posting of the quarterly public reports to the UDC website because the webmaster?s web posting audit log, which expires after 60 days, had not been retained by UDC. ? For three (3) out of six (6) reports, UDC was not able to provide evidence that the quarterly public reports were reviewed prior to posting to the UDC website because the evidence had not been retained by UDC. UDC implemented its corrective action plan on June 30, 2022, and the exceptions identified above relate to reporting transactions made prior to the above-mentioned implementation date. We also examined one report made post the above-mentioned implementation date and we noted that UDC had kept all evidence of review of the report and the evidence of the report being published in the UDC website. Questioned Costs ? None. Context ? This is a condition identified per review of UDC?s compliance with specified reporting requirements related to the program using a statistically valid sample. Effect ? Without adequate controls in place to ensure that reports are posted timely and proof that the reports were reviewed leads to noncompliance of the reporting requirements under the program. Cause ? UDC does not have adequate controls in place to ensure that documents are maintained related to the review and the timely posting of reports to the UDC website. Recommendation ? We recommend for UDC to continue to maintain documentation of the timely submission of reports and proof of review of reports as required to ensure compliance with reporting requirements. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? UDC OCFO agrees with the conditions and recommendations of this finding. As noted in the condition above, UDC implemented corrective action to remediate the conditions and recommendations reported in the prior year when findings were issued. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Criteria or Specific Requirement: 2 CFR 200.328 and 31 CFR section 35.4(c) requires submission of quarterly and annual project and expenditure reports which are due to the Department of Treasury 30 days after the end of each quarter and April 30th, of the year proceeding, respectively. The project and expenditure report contains specific instructions on how to complete the report. Within the project and expenditure report, ‘Expenditure Categories’ is a critical component to be completed by reporting “obligations” and “expenditures” on each project. As defined in the report, “obligation” is an order placed (such as a contract) and similar transactions that require payment; “expenditure” is when the service has been rendered or the good has been delivered to the entity, and payment is due. Condition: Upon review and testing of the quarterly reports as submitted to the Department of Treasury, it was noted that amounts reported as expenditures for certain projects included amounts that were obligated but not yet incurred (service was not yet rendered or the good was not yet received) until a subsequent quarter. The expenditures as reported were allowable expenditures, but the timing of the expenditures was reported in the incorrect period. In addition, upon testing the expenditures as reported in the unadjusted schedule of expenditures of federal awards (the “schedule”), it was noted that $549,431 was improperly included as expenditures belonging to the fiscal year ended September 30, 2022. The expenditures identified were prematurely recorded in the general ledger since the equipment was not received until after year-end. The City’s schedule of expenditures of federal awards for the fiscal year ended September 30, 2022 required a correction to remove those amounts from the schedule and to add those amounts to the subsequent fiscal year’s schedule. Cause: The Grants Administrator’s lack of understanding of the proper manner in which the obligations and expenditures are required to be reported in the quarterly reports resulted in expenditure amounts being reported in the incorrect quarters. The City’s year-end procedures did not identify certain necessary adjustments in a timely manner in order to remove capital outlay expenditures that were incorrectly recorded during the fiscal year ended September 30, 2022 and were incorrectly included in the unadjusted schedule of expenditures of federal awards. The Grants Administrator utilized the amounts recorded as expenditures in the accounting system to prepare the quarterly reports. Expenditures should be recorded in the City’s general ledger utilizing the date services are rendered and/or goods are received. Proper monthly review of the expenditure accounts should have led to identifying expenditures that were recorded but not yet incurred. Effect or Potential Effect: The two conditions listed above resulted in differences between expenditure amounts as correctly adjusted and reported in the schedule of expenditures of federal awards, versus expenditure amounts as reported and submitted to the Department of Treasury in the quarterly reports. Future reports may be incorrectly completed if obligation amounts and expenditure amounts are not following the criteria to properly enter amounts in the quarterly reports. Questioned Costs: None. Context: During compliance testing of the reporting compliance requirement, it was noted that the total expenditures included in the schedule of expenditures of federal awards for the fiscal year ended September 30, 2022 did not agree to the total expenditures reported in the quarterly expenditure reports as submitted to the Department of Treasury for the same period. During testing of disbursements as included in the schedule of expenditures of federal awards for the major Federal program, and during internal control and compliance testing, from a total of forty-five disbursements it was noted there were four disbursements, amounting to a total of $549,431, recorded within accounts payable as capital outlay expenditures which were improperly recorded in the fiscal year ended September 30, 2022 and improperly included in the schedule of expenditures of federal awards. As evidenced by the invoice date and ship date within the invoices, the equipment was not shipped, and the equipment was not received by the City, until after year-end. The expenditures should be recorded and reported in the fiscal year ended September 30, 2023. Adjustments were made accordingly for proper recording, reporting, and presentation in the financial statements and schedule of expenditures of federal awards. Recommendation: Management should ensure year-end closing procedures are completed in a timely manner and are sufficient to assure accounts and financial statements are prepared in accordance with GAAP. If properly prepared and recorded, the subledgers for expenditures by federal awards will be generated with accurate expenditure amounts for the fiscal year. Management should assess the risk associated with this condition and identify any additional processes that can be incorporated into their existing controls to improve the deficiency; such as, minimizing the likelihood of year-end material audit adjustments through review of transactions and balances for general propriety and accuracy within one month after year-end. Follow-up and inquiries can be made timely for any transactions for which proper recording is unclear to management, if any. The Grants Administrator should maintain an up-to-date listing of expenditures by award (for all federal, state, and local awards) and should communicate with the Finance Department on a monthly basis to review the listing and determine the proper period in which the expenditures should be recorded and presented. The Grants Administrator and Finance Department should prepare a reconciliation of the expenditures as reported in the schedule of expenditures of federal awards for the major Federal program for the fiscal year ended September 30, 2022, as well as expenditures incurred from October 1, 2022 through today, and compare to the expenditures as reported in all quarterly reports through September 30, 2023. An analysis should be completed to determine the differences between the expenditures incurred by quarter versus expenditures as reported by quarter, and to determine the differences in total between expenditures incurred and expenditures reported in the quarterly and annual project and expenditure reports. The Grants Administrator should then review the Department of Treasury’s Project and Expenditure Report User Guide of State and Local Fiscal Recovery Funds, and/or contact the grantor, to determine if reports as previously submitted should be corrected for the timing difference, or to determine what the correct course of action should be.