2024-004 – Reporting Program: ALN# 47.070 = Computer and Information Science and Engineering Grant #: 2216614, 2122756, Grant Period: Year Ended December 31, 2024 Government Agency: National Science Foundation Criteria: Under 2 CFR 200.301 and 2 CFR 200.328, non-Federal entities must maintain documentation sufficient to demonstrate compliance with Federal reporting requirements, including performance and financial reporting. Per the requirements contained in 2 CFR 200.512 (a), the auditee is responsible for submitting the data collection form and the reporting package, including the auditors’ reports, within the earlier of 30 days after receipt of the auditors’ report or nine months after the end of the audit period to the federal audit clearinghouse. Condition: The Organization was unable to provide supporting documentation for the reports submitted to the Federal agency. Specifically, the Organization did not retain copies of the financial and performance reports, nor did it maintain documentation evidencing the data used to prepare those reports. The audit package and data collection form were not submitted to the Federal Audit Clearinghouse for the reporting year December 31, 2024 within nine months after the end of the audit period. Cause: The Organization’s document retention procedures are not sufficiently designed or implemented to ensure that required reporting documentation is retained in accordance with the Uniform Guidance. Account analyses were not performed in a timely manner throughout the year and this led to delays in the start of the audit process. Effect: The lack of adequate documentation increases the risk that: • Reports submitted to the funding agency may be inaccurate or incomplete. • Reporting errors may go undetected. • The Organization may be found noncompliance with Federal record retention requirements. The Organization is deficient in its submission of the required audit reporting package and data collection form. As such, the Organization is noncompliant with the reporting requirements. Questioned Costs: No questioned costs identified. Context: This sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: Yes Recommendation: We recommend that the Organization implement appropriate policies, procedures and controls to ensure that records are maintained in accordance with the applicable compliance requirements and to ensure that future submissions of the Uniform Guidance reports are filed timely. Views of Responsible Officials: See management corrective action plan attached.
Criteria or Specific Requirement: United States Code of Federal Regulation 2 CFR 200.328 requires the City to submit financial reports in a timely manner. Timeliness defined under 2 CFR 300.28 as the submission of a SF-425 Federal Financial Report no later than 30 days after a quarterly report and no later than 90 days after an annual report. Condition: The City is not in compliance with Federal requirements regarding the submission of Federal Financial Reports. Context: Audit procedures included a request for proof of SF-425 Federal Financial Report Submission. Cause: The cause for failure to submit the required Federal Financial Reports was not definitively determined, but may relate to the absence and departure of personnel previously responsible for such filings. Effect or Potential Effect: Noncompliance with this reporting requirement can lead to a reduction in future awards, if determined appropriate subsequent to a review by HUD. Questioned Costs: None. Recommendation: The City should assign responsibility for the filing of Federal Financial Reports and that submissions be verified by a second party. Federal Financial Reports not filed should be submitted. Views of Responsible Officials of the Auditee: The City will assign responsibility for the filing of the Federal Financial Reports and will verify that the reports have been submitted.
Finding 2024-02 – Untimely Submission of HUD Reports Federal Agency: U.S. Department of Housing and Urban Development (HUD) Federal Programs: • Section 8 Housing Choice Voucher Program — Assistance Listing No. 14.871 • Mainstream Voucher Program — Assistance Listing No. 14.879 • Emergency Housing Voucher Program — Assistance Listing No. 14.EHV Compliance Requirement: Reporting Type of Finding: Noncompliance and Significant Deficiency in Internal Control over Compliance Criteria: In accordance with 2 CFR §200.328(b)(1), recipients of federal awards must submit performance, financial, and program reports by the due dates prescribed by the awarding agency. HUD’s program guidance further specifies that required submissions such as the Financial Data Schedule (FDS) must be filed electronically by their respective deadlines. Timely submission of these reports enables HUD to evaluate the Authority’s financial condition, compliance with program regulations, and overall performance in administering the Housing Choice Voucher (HCV) Programs. Condition: During our testing of compliance with reporting requirements, we noted the following exceptions: The unaudited Financial Statements were submitted late The Financial Data Schedule (FDS) was submitted beyond HUD’s required submission deadline. As a result, the Authority did not fully comply with HUD’s timeliness standards for required reporting. Questioned Costs: None. Cause: The delays were primarily attributed to staff turnover and insufficient internal monitoring of submission deadlines. Failure to submit required reports on time may hinder HUD’s ability to perform timely oversight of the Authority’s operations. Persistent delays could adversely affect the Authority’s designation status or potentially impacting eligibility for certain incentives or future funding opportunities. Identification as a Repeat Finding: ☐ Yes ☑ No Recommendation: We recommend the Authority strengthen internal controls over compliance with reporting requirements by: 1. Establishing a comprehensive reporting calendar that includes all HUD submission deadlines and responsible personnel. 2. Implementing an internal review checklist that requires supervisory sign-off before each submission. 3. Setting up automated deadline reminders within the Authority’s email or compliance tracking system. 4. Providing cross-training to ensure backup staff can complete and file reports in the absence of primary personnel. These actions will promote accountability, ensure timeliness, and reduce the risk of future noncompliance. Managements Response: Management concurs with the finding. The Authority has developed a Compliance Reporting Schedule listing all required HUD submissions, their due dates, and the responsible staff. Calendar reminders and verification checkpoints have been implemented to ensure timely submissions. In addition, the Authority will conduct quarterly internal audits to confirm adherence to HUD reporting requirements. Management anticipates full corrective action by December 2025.
Finding 2024-001: 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 - 9/30/2024 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: 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 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 a repeat finding from the prior year (Finding 2023-002). As a result of the 2023 audit report, issued in February 2026, the Organization began the process of developing updated policies for compliance. In 2025, the Organization formally adopted new policies and procedures that align with the internal control standards per 2 CFR Part 200. 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 expenses, and reporting. Maintenance of written evidence supporting such reviews. Regular training and internal monitoring to ensure control procedures are consistently followed. Management response - Management agrees with this assessment and has committed to a corrective action plan. Management has also engaged with a new accounting firm to oversee the financial reporting functions at the Organization.
2 CFR 1000.10 provides that, except for the deviations set forth elsewhere in this Part, the Department of Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards set forth at 2 CFR Part 200. 2 CFR 200.302 states, in part, the financial management system of each non-Federal entity must provide for accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. 2 CFR 200.329(c)(1) states that non-Federal entities must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Reports submitted quarterly must be due no later than 30 calendar days after the reporting period. 31 CFR 35.4(c) requires recipients, in part, during the period of performance, to provide the Secretary of the U.S. Department of Treasury periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. The U.S. Department of Treasury provided supplementary information in its 2021 interim final rule on reporting requirements for State and Local Fiscal Recovery Funds for 31 CFR Part 35 and provided further guidance in its Project and Expenditure Report User Guide for State and Local Fiscal Recovery Funds. The 2021 interim rule supplementary information, part VIII states that counties will be required to submit quarterly Project and Expenditure reports through the end of the award period on December 31, 2026. The Department of Treasury’s Project and Expenditure Report User Guide provides, in part, that counties with a population that exceeds 250,000 residents must submit a Project and Expenditure Report by January 31, 2022 and then the last day of the month after the end of each quarter thereafter. The County did not have proper internal controls in place to ensure the timely and accurate submission of the Project and Expenditure Reports. During testing of Project and Expenditure Reports for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds (AL #21.027), we noted that: • The County did not submit the Project and Expenditure Reports for the second and fourth quarters by the required deadlines of July 31, 2024 and January 31, 2025, respectively. • On the first quarter Project and Expenditure Report, the County understated current period expenditures by $1,041,688, understated cumulative expenditures by $11,564,350, and understated cumulative obligations by $1,407,879. Similarly, on the third quarter Project and Expenditure Report, the County understated current period expenditures by $385.732, understated the cumulative expenditures by $13,169,950, and understated cumulative obligations by $1,407,879. Failure to have the proper controls in place to ensure the timely and accurate submission of the Project and Expenditure Reports could result in Treasury taking action against the County for failure to comply with programmatic requirements. The County should implement and have controls in place to ensure the quarterly Project and Expenditure Reports are accurate and filed by the required due dates.
ALN 14.251 Finding #2024‐009 Untimely or Incomplete Performance and Financial Reporting Repeat Finding: No Condition: The Organization did not submit required federal performance and financial reports in accordance with federal deadlines. Specifically, several required reports were either not completed, or were submitted after the required due dates set forth in the grant agreements. In some instances, supporting documentation was incomplete or insufficient. Criteria: Per 2 CFR 200.328 and 2 CFR 200.329, recipients of federal awards are required to submit performance and financial reports as required by the awarding agency. Reports must be accurate, complete, and submitted timely, in accordance with the terms and conditions of the award. Timely reporting allows federal agencies to monitor progress and ensure funds are used for authorized purposes. Cause: The Organization did not have adequate internal controls to track reporting due dates or ensure that reports were completed, reviewed, and submitted on time. Effect: Failure to submit complete and timely reports represents noncompliance with Uniform Guidance requirements and the terms of the federal awards and increases risk relating to the ability of the federal oversight agency to monitor the grant. Questioned Costs: None noted. Perspective Information: Performance and financial reports for each semi‐annual period were not submitted timely. Recommendation: We recommend that the Organization implement internal controls to ensure all required federal reports are completed accurately and submitted on time. Reporting Views of Responsible Officials: The Organization agrees with the finding. Procedures are being implemented to ensure all reports are provided to the Organization to ensure compliance with the federal grants.
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 various grant agreements for the program state that the grantee shall submit the required reports in an adequate and timely fashion. The Grantor shall provide a format for these reports and shall instruct the Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by the Grantor but shall not be construed to limit the Grantor in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to the Grantor a Status Report within 30 days of the request by the Grantor. The County submitted Final and Status Reports; however, possibly due to the failure of existing controls, three out of four (75%) of Final and Status Reports tested were submitted late and two Final Reports for projects completed in 2024 were not yet filed as of the date of this report. Reporting errors could adversely affect future grant awards. Additional controls and/or procedures should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
Criteria or Specific Requirement: The quarterly reporting requirements were stated in the "2 CFR 200.328 and 31 CFR section 35.1(c) Reporting and requests for other information" section of the Federal Register dated January 27, 2022. The US Department of Treasury requries that quarterly reports be submitted to the department if a county has a populaton below 250,000 residents and are allocated more than $10 million in SLFRF funding. The quarterly reports must be completed and submitted within the next month after the quarterly period ended. Condition: The County was not able to provide the SLFRF quarterly report to verify that the report was submitted and completed within a timely manner. Context: The County has been unable to access the SLFRF website due to the County receiving error messages that they have "insuficient access rights on cross-reference id". Questioned Costs: $0 Effect: The County was not in compliance with SLFRF reporting requirements. Cause: The County has received error messages that says they have "insufficent access rights on cross-reference id" and they cannot log-in to the SLFRF portal. Repeat: Yes, years as repeat finding - One. Auditor's Recommendation: We recommend that the County seek out assistance from the US Department of Treasury about correcting their access to the SLFRF quarterly reports. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. The County will seek out assistance so that they can obtain access to the SLFRF quarterly reports.
2024-001 – Program Reporting Requirements – Internal Control Over Compliance – Significant Deficiency (Not a Repeat Finding) Federal Programs Information: Funding Agency: Department of Health and Human Services Title: Head Start and Early Head Start (Head Start Cluster) Assistance Listing Number: 93.600 Award number: 90CI010110 Pass-through entity: Sac and Fox Nation Type of Finding: Significant Deficiency in internal control over compliance (reporting) Criteria: Per 2 CFR Part 200.328 (c), the recipient or subrecipient must submit financial reports as required by the federal award. Timely submission of these reports is essential for compliance with the terms and conditions of the federal award. Condition: During our testing, we noted that CTSA’s controls surrounding the reporting function for this program were not operating effectively to ensure that the reports were filed in a timely manner, as required by the terms of the award. Questioned Costs: None. Context: CTSA did not submit its Real Property Status Report Standard Form (SF)-429-A for the period ended November 30, 2024, due March 30, 2025, until March 31, 2025. Effect: CTSA was not in compliance with the reporting requirements of the noted program. Cause: CTSA did not have an internal control system designed to ensure all reports are submitted by the required due date. Recommendation: We recommend CTSA implement procedures to ensure timely submission of all required reports. Views of Responsible Official: See accompanying Corrective Action Plan.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
Criteria or Specific Requirement: The quarterly reporting requirements were stated in the "2 CFR 200.328 and 31 CFR section 35.1(c) Reporting and requests for other information" section of the Federal Register dated January 27, 2022. The US Department of Treasury requries that quarterly reports be submitted to the department if a county has a populaton below 250,000 residents and are allocated more than $10 million in SLFRF funding. The quarterly reports must be completed and submitted within the next month after the quarterly period ended. Condition: The County was not able to provide the SLFRF quarterly report to verify that the report was submitted and completed within a timely manner. Context: The County has been unable to access the SLFRF website due to the County receiving error messages that they have "insuficient access rights on cross-reference id". Questioned Costs: $0 Effect: The County was not in compliance with SLFRF reporting requirements. Cause: The County has received error messages that says they have "insufficent access rights on cross-reference id" and they cannot log-in to the SLFRF portal. Repeat: Yes, years as repeat finding - One. Auditor's Recommendation: We recommend that the County seek out assistance from the US Department of Treasury about correcting their access to the SLFRF quarterly reports. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. The County will seek out assistance so that they can obtain access to the SLFRF quarterly reports.
2024-001 – Program Reporting Requirements – Internal Control Over Compliance – Significant Deficiency (Not a Repeat Finding) Federal Programs Information: Funding Agency: Department of Health and Human Services Title: Head Start and Early Head Start (Head Start Cluster) Assistance Listing Number: 93.600 Award number: 90CI010110 Pass-through entity: Sac and Fox Nation Type of Finding: Significant Deficiency in internal control over compliance (reporting) Criteria: Per 2 CFR Part 200.328 (c), the recipient or subrecipient must submit financial reports as required by the federal award. Timely submission of these reports is essential for compliance with the terms and conditions of the federal award. Condition: During our testing, we noted that CTSA’s controls surrounding the reporting function for this program were not operating effectively to ensure that the reports were filed in a timely manner, as required by the terms of the award. Questioned Costs: None. Context: CTSA did not submit its Real Property Status Report Standard Form (SF)-429-A for the period ended November 30, 2024, due March 30, 2025, until March 31, 2025. Effect: CTSA was not in compliance with the reporting requirements of the noted program. Cause: CTSA did not have an internal control system designed to ensure all reports are submitted by the required due date. Recommendation: We recommend CTSA implement procedures to ensure timely submission of all required reports. Views of Responsible Official: See accompanying Corrective Action Plan.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding No.: 2024-001 Federal Financial Reports Federal Agency: National Endowment for the Humanities Federal Assistance Listing No.: 45.129 Program: Promotion of the Humanities-Federal State Partnership Requirement: Reporting Type of Finding: Significant Deficiency Federal award no. and year: SO-283113-22 Criteria: 2 CFR 200.328 states that recipients of federal awards must submit financial reports that include OMB-approved government-wide data elements which consist of the Federal Financial Report, as required by the federal award. The Federal Financial Report Instructions provided by the federal awarding agency include instructions for each line item reported in the Federal Financial Report. Condition: The amount of the federal share of expenditures line item reported in one of the Federal Financial Reports submitted in the current year was not reported in accordance with the Federal Financial Report Instructions. Context: We selected all four of the Federal Financial Reports submitted during the current year and noted that for one of the Federal Financial Reports submitted during the year, the amount reported in the federal share of expenditures line item was under reported by approximately $47,000. Cause: The Council has a process in place to support the accurate preparation and review of the Federal Financial Reports, however the Council was not diligent in following this policy. Effect: Failure to properly adhere to the processes in place over the preparation and review of the Federal Financial Reports resulted in an error to one of the submitted Federal Financial Reports. Questioned costs: None Identification of a repeat finding: N/A Recommendations: The Council should diligently follow its existing policy. Views of Responsible Official(s) and Planned Corrective Action: Management concurs with the finding. The report found lacking was reviewed by the Executive Director, and the error was based on a difference between cash and accrual accounting. Management will review federal financial reports with contracted accountants and retrieve source documents before submitting. Management will also review scope of contracted accounting services to ensure it includes review of all NEH reports.
Finding No.: 2024-001 Federal Financial Reports Federal Agency: National Endowment for the Humanities Federal Assistance Listing No.: 45.129 Program: Promotion of the Humanities-Federal State Partnership Requirement: Reporting Type of Finding: Significant Deficiency Federal award no. and year: SO-283113-22 Criteria: 2 CFR 200.328 states that recipients of federal awards must submit financial reports that include OMB-approved government-wide data elements which consist of the Federal Financial Report, as required by the federal award. The Federal Financial Report Instructions provided by the federal awarding agency include instructions for each line item reported in the Federal Financial Report. Condition: The amount of the federal share of expenditures line item reported in one of the Federal Financial Reports submitted in the current year was not reported in accordance with the Federal Financial Report Instructions. Context: We selected all four of the Federal Financial Reports submitted during the current year and noted that for one of the Federal Financial Reports submitted during the year, the amount reported in the federal share of expenditures line item was under reported by approximately $47,000. Cause: The Council has a process in place to support the accurate preparation and review of the Federal Financial Reports, however the Council was not diligent in following this policy. Effect: Failure to properly adhere to the processes in place over the preparation and review of the Federal Financial Reports resulted in an error to one of the submitted Federal Financial Reports. Questioned costs: None Identification of a repeat finding: N/A Recommendations: The Council should diligently follow its existing policy. Views of Responsible Official(s) and Planned Corrective Action: Management concurs with the finding. The report found lacking was reviewed by the Executive Director, and the error was based on a difference between cash and accrual accounting. Management will review federal financial reports with contracted accountants and retrieve source documents before submitting. Management will also review scope of contracted accounting services to ensure it includes review of all NEH reports.
Finding 2024-009 – Reporting (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Higher Education- Institutional Aid, Assistance Listing No. 84.031 Criteria: 2 CFR Part 200.328 & 329 establish reporting requirements for non-federal entities that include timely and accurate reporting. Non-federal entities are also required to establish controls over the reporting process to ensure compliance with reporting requirements. Condition: We selected 2 annual reports submitted during the year to test for controls and compliance. No documentation of review or approval of the reports was available. Cause: The College did not retain documentation of a review and approval of Title III reports submitted. Effect: The College did not have appropriate documentation. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-009 – Reporting (Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting that include timely and accurate reporting. Reporting requirements are unique to each awarding agency and criteria is based on the guidelines and regulations set forth by the funding agency. Each program required quarterly reports to be submitted. Condition: We selected nine reports for the three grant programs tested to test for timely and accurate reporting requirements. The following exceptions were noted: • Minority Health: Two Federal Financial Report (FFR) and two Federal Performance Report (FPR) reports tested; the two FFR reports were not submitted by the due date and one FFR report did not agree or reconcile to the accounting records • CDBG: Two quarterly cash reports and the FY23 Consolidated Annual Performance and Evaluation Report (CAPER) tested; the two cash on hand reports did not have supporting documentation for the amounts reported or documentation that amounts were reconciled to the City's accounting system. One cash report was also filed late. • CRF: Two project and expenditure reports tested; one was not submitted and the other was submitted late. Expenditure information for one subrecipient was underreported by $186,364. Cause: Minority Health FFR reports were not submitted until February 2025, well past the due date. In addition, one FFR was not properly supported. CDBG project profit and loss statements did not tie to the numbers on the reports, the reports were submitted based on the IDIS reports from the HUD site and were not reconciled to the general ledger. CRF subaward amounts reported did not reconcile back to the general ledger. Various reports were filed after the due date. Effect: The City did not submit timely and accurate reports in compliance with federal reporting requirements. Questioned Costs: None reported. Recommendation: The City should ensure responsible personnel have a clear understanding of the reporting guidance. The City should implement policies and procedures to monitor due dates and review all reports prepared by the grants department or its designee to ensure accurate and timely reporting. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-009 – Reporting (Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting that include timely and accurate reporting. Reporting requirements are unique to each awarding agency and criteria is based on the guidelines and regulations set forth by the funding agency. Each program required quarterly reports to be submitted. Condition: We selected nine reports for the three grant programs tested to test for timely and accurate reporting requirements. The following exceptions were noted: • Minority Health: Two Federal Financial Report (FFR) and two Federal Performance Report (FPR) reports tested; the two FFR reports were not submitted by the due date and one FFR report did not agree or reconcile to the accounting records • CDBG: Two quarterly cash reports and the FY23 Consolidated Annual Performance and Evaluation Report (CAPER) tested; the two cash on hand reports did not have supporting documentation for the amounts reported or documentation that amounts were reconciled to the City's accounting system. One cash report was also filed late. • CRF: Two project and expenditure reports tested; one was not submitted and the other was submitted late. Expenditure information for one subrecipient was underreported by $186,364. Cause: Minority Health FFR reports were not submitted until February 2025, well past the due date. In addition, one FFR was not properly supported. CDBG project profit and loss statements did not tie to the numbers on the reports, the reports were submitted based on the IDIS reports from the HUD site and were not reconciled to the general ledger. CRF subaward amounts reported did not reconcile back to the general ledger. Various reports were filed after the due date. Effect: The City did not submit timely and accurate reports in compliance with federal reporting requirements. Questioned Costs: None reported. Recommendation: The City should ensure responsible personnel have a clear understanding of the reporting guidance. The City should implement policies and procedures to monitor due dates and review all reports prepared by the grants department or its designee to ensure accurate and timely reporting. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-009 – Reporting (Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting that include timely and accurate reporting. Reporting requirements are unique to each awarding agency and criteria is based on the guidelines and regulations set forth by the funding agency. Each program required quarterly reports to be submitted. Condition: We selected nine reports for the three grant programs tested to test for timely and accurate reporting requirements. The following exceptions were noted: • Minority Health: Two Federal Financial Report (FFR) and two Federal Performance Report (FPR) reports tested; the two FFR reports were not submitted by the due date and one FFR report did not agree or reconcile to the accounting records • CDBG: Two quarterly cash reports and the FY23 Consolidated Annual Performance and Evaluation Report (CAPER) tested; the two cash on hand reports did not have supporting documentation for the amounts reported or documentation that amounts were reconciled to the City's accounting system. One cash report was also filed late. • CRF: Two project and expenditure reports tested; one was not submitted and the other was submitted late. Expenditure information for one subrecipient was underreported by $186,364. Cause: Minority Health FFR reports were not submitted until February 2025, well past the due date. In addition, one FFR was not properly supported. CDBG project profit and loss statements did not tie to the numbers on the reports, the reports were submitted based on the IDIS reports from the HUD site and were not reconciled to the general ledger. CRF subaward amounts reported did not reconcile back to the general ledger. Various reports were filed after the due date. Effect: The City did not submit timely and accurate reports in compliance with federal reporting requirements. Questioned Costs: None reported. Recommendation: The City should ensure responsible personnel have a clear understanding of the reporting guidance. The City should implement policies and procedures to monitor due dates and review all reports prepared by the grants department or its designee to ensure accurate and timely reporting. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-009 – Reporting (Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting that include timely and accurate reporting. Reporting requirements are unique to each awarding agency and criteria is based on the guidelines and regulations set forth by the funding agency. Each program required quarterly reports to be submitted. Condition: We selected nine reports for the three grant programs tested to test for timely and accurate reporting requirements. The following exceptions were noted: • Minority Health: Two Federal Financial Report (FFR) and two Federal Performance Report (FPR) reports tested; the two FFR reports were not submitted by the due date and one FFR report did not agree or reconcile to the accounting records • CDBG: Two quarterly cash reports and the FY23 Consolidated Annual Performance and Evaluation Report (CAPER) tested; the two cash on hand reports did not have supporting documentation for the amounts reported or documentation that amounts were reconciled to the City's accounting system. One cash report was also filed late. • CRF: Two project and expenditure reports tested; one was not submitted and the other was submitted late. Expenditure information for one subrecipient was underreported by $186,364. Cause: Minority Health FFR reports were not submitted until February 2025, well past the due date. In addition, one FFR was not properly supported. CDBG project profit and loss statements did not tie to the numbers on the reports, the reports were submitted based on the IDIS reports from the HUD site and were not reconciled to the general ledger. CRF subaward amounts reported did not reconcile back to the general ledger. Various reports were filed after the due date. Effect: The City did not submit timely and accurate reports in compliance with federal reporting requirements. Questioned Costs: None reported. Recommendation: The City should ensure responsible personnel have a clear understanding of the reporting guidance. The City should implement policies and procedures to monitor due dates and review all reports prepared by the grants department or its designee to ensure accurate and timely reporting. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-009 – Reporting (Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting that include timely and accurate reporting. Reporting requirements are unique to each awarding agency and criteria is based on the guidelines and regulations set forth by the funding agency. Each program required quarterly reports to be submitted. Condition: We selected nine reports for the three grant programs tested to test for timely and accurate reporting requirements. The following exceptions were noted: • Minority Health: Two Federal Financial Report (FFR) and two Federal Performance Report (FPR) reports tested; the two FFR reports were not submitted by the due date and one FFR report did not agree or reconcile to the accounting records • CDBG: Two quarterly cash reports and the FY23 Consolidated Annual Performance and Evaluation Report (CAPER) tested; the two cash on hand reports did not have supporting documentation for the amounts reported or documentation that amounts were reconciled to the City's accounting system. One cash report was also filed late. • CRF: Two project and expenditure reports tested; one was not submitted and the other was submitted late. Expenditure information for one subrecipient was underreported by $186,364. Cause: Minority Health FFR reports were not submitted until February 2025, well past the due date. In addition, one FFR was not properly supported. CDBG project profit and loss statements did not tie to the numbers on the reports, the reports were submitted based on the IDIS reports from the HUD site and were not reconciled to the general ledger. CRF subaward amounts reported did not reconcile back to the general ledger. Various reports were filed after the due date. Effect: The City did not submit timely and accurate reports in compliance with federal reporting requirements. Questioned Costs: None reported. Recommendation: The City should ensure responsible personnel have a clear understanding of the reporting guidance. The City should implement policies and procedures to monitor due dates and review all reports prepared by the grants department or its designee to ensure accurate and timely reporting. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-009 – Reporting (Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting that include timely and accurate reporting. Reporting requirements are unique to each awarding agency and criteria is based on the guidelines and regulations set forth by the funding agency. Each program required quarterly reports to be submitted. Condition: We selected nine reports for the three grant programs tested to test for timely and accurate reporting requirements. The following exceptions were noted: • Minority Health: Two Federal Financial Report (FFR) and two Federal Performance Report (FPR) reports tested; the two FFR reports were not submitted by the due date and one FFR report did not agree or reconcile to the accounting records • CDBG: Two quarterly cash reports and the FY23 Consolidated Annual Performance and Evaluation Report (CAPER) tested; the two cash on hand reports did not have supporting documentation for the amounts reported or documentation that amounts were reconciled to the City's accounting system. One cash report was also filed late. • CRF: Two project and expenditure reports tested; one was not submitted and the other was submitted late. Expenditure information for one subrecipient was underreported by $186,364. Cause: Minority Health FFR reports were not submitted until February 2025, well past the due date. In addition, one FFR was not properly supported. CDBG project profit and loss statements did not tie to the numbers on the reports, the reports were submitted based on the IDIS reports from the HUD site and were not reconciled to the general ledger. CRF subaward amounts reported did not reconcile back to the general ledger. Various reports were filed after the due date. Effect: The City did not submit timely and accurate reports in compliance with federal reporting requirements. Questioned Costs: None reported. Recommendation: The City should ensure responsible personnel have a clear understanding of the reporting guidance. The City should implement policies and procedures to monitor due dates and review all reports prepared by the grants department or its designee to ensure accurate and timely reporting. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-008 – Reporting (Material Weakness) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting. 2 CFR 200.303 requires nonfederal entities to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Typical control procedures related to reporting are to verify the filed report is supported by supporting documentation and inspecting filed report and supporting documentation, noting supervisory review of reports performed to assure accuracy and completeness of data and information included in the report. Condition: We selected nine reports for the three grant programs tested to test for controls over reporting requirements. No documentation of review or approval of the reports was available. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-009 – Reporting (Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting that include timely and accurate reporting. Reporting requirements are unique to each awarding agency and criteria is based on the guidelines and regulations set forth by the funding agency. Each program required quarterly reports to be submitted. Condition: We selected nine reports for the three grant programs tested to test for timely and accurate reporting requirements. The following exceptions were noted: • Minority Health: Two Federal Financial Report (FFR) and two Federal Performance Report (FPR) reports tested; the two FFR reports were not submitted by the due date and one FFR report did not agree or reconcile to the accounting records • CDBG: Two quarterly cash reports and the FY23 Consolidated Annual Performance and Evaluation Report (CAPER) tested; the two cash on hand reports did not have supporting documentation for the amounts reported or documentation that amounts were reconciled to the City's accounting system. One cash report was also filed late. • CRF: Two project and expenditure reports tested; one was not submitted and the other was submitted late. Expenditure information for one subrecipient was underreported by $186,364. Cause: Minority Health FFR reports were not submitted until February 2025, well past the due date. In addition, one FFR was not properly supported. CDBG project profit and loss statements did not tie to the numbers on the reports, the reports were submitted based on the IDIS reports from the HUD site and were not reconciled to the general ledger. CRF subaward amounts reported did not reconcile back to the general ledger. Various reports were filed after the due date. Effect: The City did not submit timely and accurate reports in compliance with federal reporting requirements. Questioned Costs: None reported. Recommendation: The City should ensure responsible personnel have a clear understanding of the reporting guidance. The City should implement policies and procedures to monitor due dates and review all reports prepared by the grants department or its designee to ensure accurate and timely reporting. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Reference Number: 2024-003 L. Reporting Compliance Requirement ALN 21.027 Coronavirus State and Local Fiscal Recovery Fund Federal Award Agreement Number: 17460025442 Award Year: 2023-2024 Federal Agency: U.S. Department of Treasury Criteria: Non-federal entities are required to establish and maintain effective internal controls over compliance in accordance with 2 CFR 200.328 and 31 CFR section 35.4 (c), states metropolitan cities and counties with a population below 250,000 residents that are allocated more than $10 million in SLFRF funding are required to submit quarterly Project and Expenditure Reports. Condition Found: During our review of the quarterly reporting process, CRI identified two quarterly reports that did not reflect current quarterly activity and no documentation was maintained to support evidence that the report was reviewed. Cause: Documentation of review and accurate submission regarding Q1 and Q2 2024 project and expenditure reports were not maintained. Effect: The Department of Treasury uses the reports internally for oversight purposes and to fulfill Treasury’s transparency and legal obligations. The results of the City not correctly submitting a report timely could lead to a finding of non-compliance, which could result in development of corrective action plan or other consequences. Questioned Cost: $0 Recommendation: We recommend the City to document and maintain all proper controls and review of all quarterly reports that are submitted through the portal to ensure complete and accurate reports. Views of Responsible Officials: Management agrees with the findings. See corrective action plan beginning on page 230.
Criteria: 2 CFR Section 200.328 requires that the non-federal entity must submit the Federal Financial Report (SF-425) no later than 30 days after the end of a quarterly or semiannually reporting period (or 90 days for annual reporting periods). Condition and context: During testing of the Alliance’s compliance over reporting, we identified the Alliance did not submit the SF-425 forms timely during the year ended September 30, 2024. Cause: The Alliance’s controls and processes were not effectively designed to ensure all reporting requirements are executed timely. Effect: The Alliance was not fully in compliance with the reporting requirements of the Uniform Guidance. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Alliance implement internal controls such as a compliance calendar and designated review procedures to ensure that all federal reporting requirements, including SF-425 filings, are completed accurately and on time. Views of Responsible Official: Management agrees with the finding. See Corrective Action Plan.
Finding 2024-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Program Name: Multiple federal programs Criteria 1. The code of federal regulations – 2 CFR 200.302 Financial management requires that: (a) Each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State’s funds. All recipient and subrecipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) The recipient’s and subrecipient’s financial management system must provide for the following: (1) Identification of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number, year the Federal award was issued, and name of the Federal agency or pass-through entity. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in § 200.328 and § 200.329. When a Federal agency or pass-through entity requires reporting on an accrual basis from a recipient or subrecipient that maintains its records other than on an accrual basis, the recipient or subrecipient must not be required to establish an accrual accounting system. This recipient or subrecipient may develop accrual data for its reports based on an analysis of the documentation on hand. 2. The code of federal regulations – 2 CFR 200.303 Internal controls requires that recipients and subrecipients must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award. (c) Evaluate and monitor the recipient’s or subrecipient’s compliance with statutes, regulations, and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified. Condition The following exceptions to the criteria were observed during the performance of the audit procedures: 1. After the completion of internal review and approval process that Amtrak has established for SEFA preparation and review, we have received multiple updated versions of the schedule with changes to FY24 expenditure amounts for three Assistance Listings included on the SEFA. Total expenditures increased by $80.2 million from version 1 to the final version received. 2. The starting point of the SEFA preparation for the current year was not the audited FY23 SEFA submitted to Federal Audit Clearinghouse, as we have identified that Amtrak subsequently made changes to the FY23 internal SEFA document without reconciling the changes to the audited FY23 SEFA, which resulted in the total cumulative expenditures as of 9/30/2023 to be updated and as such impacting the FY24 expenditures for the respective federal programs. One of the adjustments related to the Hudson Yards Concrete Casing project (HYCC-3) which initially incorrectly recorded $25.0 million of prepaid expenditures. 3. As Assistance Listing #20.314 has been obligated as of 9/27/2024, Amtrak has recorded expenditures related to the HYCC-3 project under this program for the established pre-award period, which dated from January 30, 2023 as part of the FY24 expenditures. Previously, a portion of the total expenditures was included within the FY23 SEFA under Assistance Listing #20.315, for the total amount of $15.6 million. This amount was not adjusted out of the cumulative expenditures for Assistance Listing #20.315 until 2025. Consequently, these expenditures were listed both within the FY23 SEFA under Assistance Listing #20.315 and under the FY24 SEFA as Assistance Listing #20.314 expenditures. 4. As part of SEFA preparation as it relates to allocation of operating expenditures across multiple funding sources, certain projects were incorrectly mapped to annual grants funding source, which resulted in approximately $0.3 million of operating expenses to be included within Assistance Listing #20.315 that were also reported under Assistance Listing #97.075. Cause Amtrak’s control procedures in place as it relates to the preparation of the SEFA were not operating in a manner that would timely identify the conditions noted. Additionally, Amtrak’s controls around allocation of federal funding to project codes were not designed in a manner that would timely identify the conditions noted. In reviewing management’s controls around the SEFA preparation, the design of key controls identified by management does not include an overarching review of the SEFA and reconciliation of what’s been reported on the SEFA from individual projects’ standpoint when such projects have multiple assistance listings as funding sources. We also noted that there was not a specific control that ensures timely updates of Work Breakdown Structure (WBS) funding assignments and allocations when there is a change such as a new grant agreement signed. Effect Amtrak’s control procedures in place as it relates to the preparation of the SEFA were not designed in such a manner that would timely identify the conditions noted, which resulted in several versions of the SEFA that were erroneous and inclusion of expenditures that were double counted within the SEFA. This puts Amtrak at greater risk of non-compliance with its grant agreements with respect to questioned costs and an inaccurate SEFA. Questioned Costs None. Context The SEFA, as originally provided, had exceptions as described in the Condition section above noted for matters 1 and 2 in the Criteria section above, indicating that certain internal controls were not functioning as designed and others were not designed effectively. Identification as a Repeat Finding Not a repeat finding. Recommendation We recommend Amtrak to strengthen the SEFA oversight process to ensure appropriate preparation and review of the SEFA to validate its accuracy, including reconciliation with prior year audited SEFA. This should include having one reviewer take overall responsibility for the completeness and accuracy of the final submitted SEFA. This robust review process should include appropriate procedures to confirm accuracy of the SEFA, which may include a protocol where representatives from various groups (both discretionary and non-discretionary federal programs) work collaboratively to review the SEFA and underlying details of expenditures, to ensure all the adjustments have been properly reflected as well as any projects that might have multiple fund sources are identified timely and reviewed for appropriate inclusion within the SEFA. Additionally, Amtrak should establish a process where any modifications of WBS funding assignments and allocations are updated in a timely manner. Views of Responsible Officials Amtrak recognizes the need to improve the preparation and review of the SEFA. The company has documented the steps for preparing and reviewing the SEFA within its process narrative. The company will update the narrative to address the preparation and review issues that led to the multiple versions of the SEFA being provided during the audit. The company will review and update the Grants Management Compliance Narrative and controls to improve timing of updates for modifications of WBS funding assignments. The company is in the process of updating the SEFA preparation documentation for FY2025, which will be used at the end of the year. The review procedures and controls are being enhanced to include a checklist to improve the review.
Finding 2024-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Program Name: Multiple federal programs Criteria 1. The code of federal regulations – 2 CFR 200.302 Financial management requires that: (a) Each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State’s funds. All recipient and subrecipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) The recipient’s and subrecipient’s financial management system must provide for the following: (1) Identification of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number, year the Federal award was issued, and name of the Federal agency or pass-through entity. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in § 200.328 and § 200.329. When a Federal agency or pass-through entity requires reporting on an accrual basis from a recipient or subrecipient that maintains its records other than on an accrual basis, the recipient or subrecipient must not be required to establish an accrual accounting system. This recipient or subrecipient may develop accrual data for its reports based on an analysis of the documentation on hand. 2. The code of federal regulations – 2 CFR 200.303 Internal controls requires that recipients and subrecipients must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award. (c) Evaluate and monitor the recipient’s or subrecipient’s compliance with statutes, regulations, and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified. Condition The following exceptions to the criteria were observed during the performance of the audit procedures: 1. After the completion of internal review and approval process that Amtrak has established for SEFA preparation and review, we have received multiple updated versions of the schedule with changes to FY24 expenditure amounts for three Assistance Listings included on the SEFA. Total expenditures increased by $80.2 million from version 1 to the final version received. 2. The starting point of the SEFA preparation for the current year was not the audited FY23 SEFA submitted to Federal Audit Clearinghouse, as we have identified that Amtrak subsequently made changes to the FY23 internal SEFA document without reconciling the changes to the audited FY23 SEFA, which resulted in the total cumulative expenditures as of 9/30/2023 to be updated and as such impacting the FY24 expenditures for the respective federal programs. One of the adjustments related to the Hudson Yards Concrete Casing project (HYCC-3) which initially incorrectly recorded $25.0 million of prepaid expenditures. 3. As Assistance Listing #20.314 has been obligated as of 9/27/2024, Amtrak has recorded expenditures related to the HYCC-3 project under this program for the established pre-award period, which dated from January 30, 2023 as part of the FY24 expenditures. Previously, a portion of the total expenditures was included within the FY23 SEFA under Assistance Listing #20.315, for the total amount of $15.6 million. This amount was not adjusted out of the cumulative expenditures for Assistance Listing #20.315 until 2025. Consequently, these expenditures were listed both within the FY23 SEFA under Assistance Listing #20.315 and under the FY24 SEFA as Assistance Listing #20.314 expenditures. 4. As part of SEFA preparation as it relates to allocation of operating expenditures across multiple funding sources, certain projects were incorrectly mapped to annual grants funding source, which resulted in approximately $0.3 million of operating expenses to be included within Assistance Listing #20.315 that were also reported under Assistance Listing #97.075. Cause Amtrak’s control procedures in place as it relates to the preparation of the SEFA were not operating in a manner that would timely identify the conditions noted. Additionally, Amtrak’s controls around allocation of federal funding to project codes were not designed in a manner that would timely identify the conditions noted. In reviewing management’s controls around the SEFA preparation, the design of key controls identified by management does not include an overarching review of the SEFA and reconciliation of what’s been reported on the SEFA from individual projects’ standpoint when such projects have multiple assistance listings as funding sources. We also noted that there was not a specific control that ensures timely updates of Work Breakdown Structure (WBS) funding assignments and allocations when there is a change such as a new grant agreement signed. Effect Amtrak’s control procedures in place as it relates to the preparation of the SEFA were not designed in such a manner that would timely identify the conditions noted, which resulted in several versions of the SEFA that were erroneous and inclusion of expenditures that were double counted within the SEFA. This puts Amtrak at greater risk of non-compliance with its grant agreements with respect to questioned costs and an inaccurate SEFA. Questioned Costs None. Context The SEFA, as originally provided, had exceptions as described in the Condition section above noted for matters 1 and 2 in the Criteria section above, indicating that certain internal controls were not functioning as designed and others were not designed effectively. Identification as a Repeat Finding Not a repeat finding. Recommendation We recommend Amtrak to strengthen the SEFA oversight process to ensure appropriate preparation and review of the SEFA to validate its accuracy, including reconciliation with prior year audited SEFA. This should include having one reviewer take overall responsibility for the completeness and accuracy of the final submitted SEFA. This robust review process should include appropriate procedures to confirm accuracy of the SEFA, which may include a protocol where representatives from various groups (both discretionary and non-discretionary federal programs) work collaboratively to review the SEFA and underlying details of expenditures, to ensure all the adjustments have been properly reflected as well as any projects that might have multiple fund sources are identified timely and reviewed for appropriate inclusion within the SEFA. Additionally, Amtrak should establish a process where any modifications of WBS funding assignments and allocations are updated in a timely manner. Views of Responsible Officials Amtrak recognizes the need to improve the preparation and review of the SEFA. The company has documented the steps for preparing and reviewing the SEFA within its process narrative. The company will update the narrative to address the preparation and review issues that led to the multiple versions of the SEFA being provided during the audit. The company will review and update the Grants Management Compliance Narrative and controls to improve timing of updates for modifications of WBS funding assignments. The company is in the process of updating the SEFA preparation documentation for FY2025, which will be used at the end of the year. The review procedures and controls are being enhanced to include a checklist to improve the review.
2024-002 - Late Submission of Reports Finding Type. Immaterial Noncompliance; Significant Deficiency over Compliance (Reporting). Program. VA Supportive Services for Veteran Families Program; Department of Veterans Affairs, Assistance Listing Number 64.033; All Award Numbers. Criteria. Per 2 CFR Part 200.328 (c), the recipient or subrecipient must submit financial reports as required by the federal award. Timely submission of these reports is essential for compliance with the terms and conditions of the federal award. Condition. The Agency failed to submit the required report for the federal grant within the stipulated deadlines as outlined in the grant agreement and Uniform Guidance. During reporting testing, it was noted that the Final FFR report was not submitted into the Payment Management Services (PMS) prior to the required due date. Cause. The delay in reporting was due to inadequate internal controls over the grant management process, including insufficient staffing and lack of proper training for personnel responsible for preparing and submitting the reports. Processes in place were not sufficient to prevent the report from being submitted late. Effect. Late submission of reports results in noncompliance with federal regulations, potentially leading to administrative actions such as withholding of future grant funds, increased monitoring, or other penalties as deemed appropriate by the Federal awarding agency. The Agency did not comply with contractual reporting requirements. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend the Agency implement procedures to ensure timely submission of all required reports. View of Responsible Official. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-002 - Late Submission of Reports Finding Type. Immaterial Noncompliance; Significant Deficiency over Compliance (Reporting). Program. VA Supportive Services for Veteran Families Program; Department of Veterans Affairs, Assistance Listing Number 64.033; All Award Numbers. Criteria. Per 2 CFR Part 200.328 (c), the recipient or subrecipient must submit financial reports as required by the federal award. Timely submission of these reports is essential for compliance with the terms and conditions of the federal award. Condition. The Agency failed to submit the required report for the federal grant within the stipulated deadlines as outlined in the grant agreement and Uniform Guidance. During reporting testing, it was noted that the Final FFR report was not submitted into the Payment Management Services (PMS) prior to the required due date. Cause. The delay in reporting was due to inadequate internal controls over the grant management process, including insufficient staffing and lack of proper training for personnel responsible for preparing and submitting the reports. Processes in place were not sufficient to prevent the report from being submitted late. Effect. Late submission of reports results in noncompliance with federal regulations, potentially leading to administrative actions such as withholding of future grant funds, increased monitoring, or other penalties as deemed appropriate by the Federal awarding agency. The Agency did not comply with contractual reporting requirements. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend the Agency implement procedures to ensure timely submission of all required reports. View of Responsible Official. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-002 - Late Submission of Reports Finding Type. Immaterial Noncompliance; Significant Deficiency over Compliance (Reporting). Program. VA Supportive Services for Veteran Families Program; Department of Veterans Affairs, Assistance Listing Number 64.033; All Award Numbers. Criteria. Per 2 CFR Part 200.328 (c), the recipient or subrecipient must submit financial reports as required by the federal award. Timely submission of these reports is essential for compliance with the terms and conditions of the federal award. Condition. The Agency failed to submit the required report for the federal grant within the stipulated deadlines as outlined in the grant agreement and Uniform Guidance. During reporting testing, it was noted that the Final FFR report was not submitted into the Payment Management Services (PMS) prior to the required due date. Cause. The delay in reporting was due to inadequate internal controls over the grant management process, including insufficient staffing and lack of proper training for personnel responsible for preparing and submitting the reports. Processes in place were not sufficient to prevent the report from being submitted late. Effect. Late submission of reports results in noncompliance with federal regulations, potentially leading to administrative actions such as withholding of future grant funds, increased monitoring, or other penalties as deemed appropriate by the Federal awarding agency. The Agency did not comply with contractual reporting requirements. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend the Agency implement procedures to ensure timely submission of all required reports. View of Responsible Official. Management agrees with this finding and has prepared a Corrective Action Plan.
Criteria: Per Title 2 CFR § 200.328, the recipient must submit annual financial reports no later than 90 calendar days after the reporting period, and semi-annual reports no later than 30 days after the reporting period. Condition: The semi-annual SF-425 financial report was not submitted timely. Cause: The semi-annual SF-425 financial report was not submitted within the 30-day timeframe as required by the Head Start Grant Program. Effect or Potential Effect: Late submissions resulted in non-compliance with reporting requirements and could result in loss or reduction of funding for the program. Context: The semi-annual SF-425 financial report was not filed within 30-days of period end as required in the grant agreement. Recommendation: We recommend that the Organization implement procedure to ensure compliance with filing requirements. Views of Management: Management acknowledges the lapse in regularly meeting the grant requirement of submitting financial reports within the specified 30-day period. To address this issue, the Organization has initiated a comprehensive procedural shift.
Criteria or Specific Requirements: In accordance with 2 CFR §170, prime awardees awarded a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Further, the Organization is subject to reporting requirements for both financial and progress reporting. In accordance with 2 CFR §200.328, Federal Financial Reports (FFR) should be submitted based on frequency required by the terms and conditions. Under grant agreements, program 10.761 and 66.446 require both financial and performance reports to be submitted quarterly within 12 days after quarter-end, while ALN program 93.570 requires semiannual financial and performance reports within 30 days after period-end. Condition: During the review of reporting compliance for the major programs, it was determined that the Organization did not file the FFATA report for program 93.570 within the required 30-day period, and did not submit quarterly financial reports for program 10.761 within the required 12-day deadline after quarter-end. Cause: Internal controls over financial reporting were not operating effectively to file the FFATA report a timely manner. Management was not aware of the FFATA requirements for prime awards. Further, internal controls over financial reporting were not operating effectively to file financial reports in a timely manner. Effect: Failure to submit the FFATA report by the end of the month following award of a subgrant over $30,000 results in noncompliance with 2 CFR § 170. Additionally, failure to submit quarterly financial reports for program 10.761 within the required deadline constitutes noncompliance with the Federal Financial Reporting requirement under 2 CFR § 200.328. Questioned Costs: Questioned costs were not identified. Perspective information: It is noted that the Organization has not established policies and procedures that will ensure that FFATA reports are submitted within the required timeline and therefore one out of one samples tested for this compliance requirement were not completed. Further, for program 10.761 quarterly financial reports, one out of two samples tested – drawn from a population of 10 – was not submitted within the required 12-day time frame. Noncompliance surrounding reporting was identified for the following awards during the fiscal 2024: Federal Agency Pass-Through Entity ALN Federal Award Name Award Year Department of Health and Human Services Direct 93.570 HHS RCD 9/30/2023 – 9/29/2024 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Technitrain 2023 – 2024 9/1/2023 – 9/30/2026 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Tribal 2023 - 2024 9/1/2023 – 9/30/2026 Repeat Finding: Yes – Repeat of FY 2024 Finding 2023-005. Recommendations: We recommend that management and relevant staff participate in comprehensive training on federal grant compliance—emphasizing FFATA obligations and financial reporting deadlines—to ensure a clear understanding of requirements. Management should then formalize and document procedures for FFATA reporting, including a calendar-driven workflow with designated preparers and approvers, mandatory sign-off checklists, and automated reminders. Finally, the Organization should implement a centralized reporting-tracking system that monitors all federal award deadlines and captures evidence of timely preparation, review, and submission for both financial and performance reports.
Criteria or Specific Requirements: In accordance with 2 CFR §170, prime awardees awarded a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Further, the Organization is subject to reporting requirements for both financial and progress reporting. In accordance with 2 CFR §200.328, Federal Financial Reports (FFR) should be submitted based on frequency required by the terms and conditions. Under grant agreements, program 10.761 and 66.446 require both financial and performance reports to be submitted quarterly within 12 days after quarter-end, while ALN program 93.570 requires semiannual financial and performance reports within 30 days after period-end. Condition: During the review of reporting compliance for the major programs, it was determined that the Organization did not file the FFATA report for program 93.570 within the required 30-day period, and did not submit quarterly financial reports for program 10.761 within the required 12-day deadline after quarter-end. Cause: Internal controls over financial reporting were not operating effectively to file the FFATA report a timely manner. Management was not aware of the FFATA requirements for prime awards. Further, internal controls over financial reporting were not operating effectively to file financial reports in a timely manner. Effect: Failure to submit the FFATA report by the end of the month following award of a subgrant over $30,000 results in noncompliance with 2 CFR § 170. Additionally, failure to submit quarterly financial reports for program 10.761 within the required deadline constitutes noncompliance with the Federal Financial Reporting requirement under 2 CFR § 200.328. Questioned Costs: Questioned costs were not identified. Perspective information: It is noted that the Organization has not established policies and procedures that will ensure that FFATA reports are submitted within the required timeline and therefore one out of one samples tested for this compliance requirement were not completed. Further, for program 10.761 quarterly financial reports, one out of two samples tested – drawn from a population of 10 – was not submitted within the required 12-day time frame. Noncompliance surrounding reporting was identified for the following awards during the fiscal 2024: Federal Agency Pass-Through Entity ALN Federal Award Name Award Year Department of Health and Human Services Direct 93.570 HHS RCD 9/30/2023 – 9/29/2024 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Technitrain 2023 – 2024 9/1/2023 – 9/30/2026 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Tribal 2023 - 2024 9/1/2023 – 9/30/2026 Repeat Finding: Yes – Repeat of FY 2024 Finding 2023-005. Recommendations: We recommend that management and relevant staff participate in comprehensive training on federal grant compliance—emphasizing FFATA obligations and financial reporting deadlines—to ensure a clear understanding of requirements. Management should then formalize and document procedures for FFATA reporting, including a calendar-driven workflow with designated preparers and approvers, mandatory sign-off checklists, and automated reminders. Finally, the Organization should implement a centralized reporting-tracking system that monitors all federal award deadlines and captures evidence of timely preparation, review, and submission for both financial and performance reports.
Criteria or Specific Requirements: In accordance with 2 CFR §170, prime awardees awarded a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Further, the Organization is subject to reporting requirements for both financial and progress reporting. In accordance with 2 CFR §200.328, Federal Financial Reports (FFR) should be submitted based on frequency required by the terms and conditions. Under grant agreements, program 10.761 and 66.446 require both financial and performance reports to be submitted quarterly within 12 days after quarter-end, while ALN program 93.570 requires semiannual financial and performance reports within 30 days after period-end. Condition: During the review of reporting compliance for the major programs, it was determined that the Organization did not file the FFATA report for program 93.570 within the required 30-day period, and did not submit quarterly financial reports for program 10.761 within the required 12-day deadline after quarter-end. Cause: Internal controls over financial reporting were not operating effectively to file the FFATA report a timely manner. Management was not aware of the FFATA requirements for prime awards. Further, internal controls over financial reporting were not operating effectively to file financial reports in a timely manner. Effect: Failure to submit the FFATA report by the end of the month following award of a subgrant over $30,000 results in noncompliance with 2 CFR § 170. Additionally, failure to submit quarterly financial reports for program 10.761 within the required deadline constitutes noncompliance with the Federal Financial Reporting requirement under 2 CFR § 200.328. Questioned Costs: Questioned costs were not identified. Perspective information: It is noted that the Organization has not established policies and procedures that will ensure that FFATA reports are submitted within the required timeline and therefore one out of one samples tested for this compliance requirement were not completed. Further, for program 10.761 quarterly financial reports, one out of two samples tested – drawn from a population of 10 – was not submitted within the required 12-day time frame. Noncompliance surrounding reporting was identified for the following awards during the fiscal 2024: Federal Agency Pass-Through Entity ALN Federal Award Name Award Year Department of Health and Human Services Direct 93.570 HHS RCD 9/30/2023 – 9/29/2024 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Technitrain 2023 – 2024 9/1/2023 – 9/30/2026 United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Tribal 2023 - 2024 9/1/2023 – 9/30/2026 Repeat Finding: Yes – Repeat of FY 2024 Finding 2023-005. Recommendations: We recommend that management and relevant staff participate in comprehensive training on federal grant compliance—emphasizing FFATA obligations and financial reporting deadlines—to ensure a clear understanding of requirements. Management should then formalize and document procedures for FFATA reporting, including a calendar-driven workflow with designated preparers and approvers, mandatory sign-off checklists, and automated reminders. Finally, the Organization should implement a centralized reporting-tracking system that monitors all federal award deadlines and captures evidence of timely preparation, review, and submission for both financial and performance reports.
Finding 2024-005 – REPORTING (repeat finding) Type: Material Weakness in Internal Control/Noncompliance. Program: ALN 93.493 Congressional Directives Grant Name: Access to Behavioral Crisis Services Grantor Number: FG-22-099 Criteria: Pursuant to 2 CFR 200.328(c), “The recipient or subrecipient must submit financial reports as required by the Federal award.” According to the closeout requirements of the Federal award, recipients must, “Reconcile financial expenditures to the reported total disbursement and charges in PMS.” Condition: The CMHSP did not file the required annual Federal Financial Report as required for this grant. Cause: This condition was caused by an insufficient internal control process for grant reporting. Effect: Reporting requirements required by the grant were not met. Questioned Cost: None. Context: Amounts received as Federal reimbursement, as detailed in PMS, were supported by the CMHSP’s internal records. However, the final report of expenses was never submitted. Recommendation: We recommend that the CMHSP review their internal controls and make necessary changes to ensure that reports are filed in accordance with the grant requirements. Management’s Resp: We are in agreement with this finding.