CLAYTON COUNTY COMMUNITY SERVICES AUTHORITY, INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS Financial Statement Findings and Questioned Costs June 30, 2021 Comment #2021-001 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, PROPER APPROVAL OF DISBURSEMENTS, GRANT CLOSE-OUT PROCEDURES AND REQUIRED REGULATORY REPORTING POLICIES AND PROCEDURES SHOULD IMPROVED GENERAL (Repeat Finding) As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Authority. The preparation of these financial statements in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards state in summary, that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The closeout process is designed to help to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity of the current staff does not allow for adequate analysis of grants and contracts, other internal shared costs and support services provided, grantor receivables, deferred revenue, allocation of indirect costs and the reconciliation of bank accounts accurately and in a timely manner. Various regulatory reports were not filed accurately and in a timely manner (i.e., SF-425's for the Head Start Programs and DHS’s State budget reports for the LIHEAP programs). Specifically, revenue was recorded in excess of expenditures for the LIHEAP programs. Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually), which is consistent with our audit findings for the year ended June 30, 2020. The systemic cause appears to be a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of accounting controls, monitoring and policies and procedures not followed consistently. Context: Review of internal control structure of the organization in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§200.327 Financial reporting and 200.328 Monitoring and reporting program performance. [2 CFR §200.302(b)(2)] Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes. Cause: Limited personnel with knowledge and/or the ability to assist and provide needed information to aid in financial statement preparation. The implementation of a new accounting system without an adequate close-out of the old system. Recommendation: The degree to which the preparation of the financial statements and related disclosures are prepared by the independent auditor is a control deficiency is determined by the knowledge, skills and experience of those in the organization who are charged with the responsibility of its financial reporting. The Authority has a chief financial officer (CFO) and should hire additional staff (grant accountant and a general ledger accountant) to assist the new fiscal officer. The workload on the CFO is overwhelming. New staff hired should have the adequate skills, knowledge and experience to oversee and/or perform the necessary accounting functions each month. We believe that the CFO with the grant accountant and general ledger accountant should have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner so as to eliminate the risk of significant errors occurring. Budget-to-actual schedules should be an integral part of the grant accountant’s basic responsibilities. We further recommend that training be provided to all staff engaged in the financial reporting, allocation and reconciliation functions to ensure that a complete and accurate financial statements close-out process is achieved each month and annually. New policies and procedures should be established that conforms to the Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions: The management of Clayton County Community Services Authority, Inc. has reviewed the above referenced finding and fully agrees with the need for improved internal controls over financial statement preparation. Management believes that the proper approval of disbursements was adhered to during the reporting period with minimal deviation and continues to ensure proper policies are followed. Federal reports (SF425’s, LIHEAP) were filed during this period and may not have been properly reviewed during the course of this audit. For example, the LIHEAP reports were reconciled with the assistance of the State Program Specialist to ensure proper return of funds as requested by the funding agency. Management reserves the right to discuss this further as needed for the purpose of this finding. Adequate fiscal personnel staff has continued to be a challenge for the agency as management has done an exhaustive search for additional fiscal personnel and made job offers to qualified individuals only to have them decline the offer at the last moment. We have just offered the position of General Ledger Accountant to an individual and they are expected to start in two weeks. This will assist the CFO in the area of financial controls and reporting. It should also be noted that all bank reconciliations are current and being completed in a timely manner as dictated by our policies and procedures. Management continues to ensure all federal, state, and local and local regulatory reports and completed and submitted in a timely manner. As stated previously, the CFO worked directly with the State LIHEAP Program Staff to ensure proper reporting and reconciliation before returning unused funds.
CLAYTON COUNTY COMMUNITY SERVICES AUTHORITY, INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS Financial Statement Findings and Questioned Costs June 30, 2021 Comment #2021-001 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, PROPER APPROVAL OF DISBURSEMENTS, GRANT CLOSE-OUT PROCEDURES AND REQUIRED REGULATORY REPORTING POLICIES AND PROCEDURES SHOULD IMPROVED GENERAL (Repeat Finding) As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Authority. The preparation of these financial statements in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards state in summary, that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The closeout process is designed to help to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity of the current staff does not allow for adequate analysis of grants and contracts, other internal shared costs and support services provided, grantor receivables, deferred revenue, allocation of indirect costs and the reconciliation of bank accounts accurately and in a timely manner. Various regulatory reports were not filed accurately and in a timely manner (i.e., SF-425's for the Head Start Programs and DHS’s State budget reports for the LIHEAP programs). Specifically, revenue was recorded in excess of expenditures for the LIHEAP programs. Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually), which is consistent with our audit findings for the year ended June 30, 2020. The systemic cause appears to be a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of accounting controls, monitoring and policies and procedures not followed consistently. Context: Review of internal control structure of the organization in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§200.327 Financial reporting and 200.328 Monitoring and reporting program performance. [2 CFR §200.302(b)(2)] Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes. Cause: Limited personnel with knowledge and/or the ability to assist and provide needed information to aid in financial statement preparation. The implementation of a new accounting system without an adequate close-out of the old system. Recommendation: The degree to which the preparation of the financial statements and related disclosures are prepared by the independent auditor is a control deficiency is determined by the knowledge, skills and experience of those in the organization who are charged with the responsibility of its financial reporting. The Authority has a chief financial officer (CFO) and should hire additional staff (grant accountant and a general ledger accountant) to assist the new fiscal officer. The workload on the CFO is overwhelming. New staff hired should have the adequate skills, knowledge and experience to oversee and/or perform the necessary accounting functions each month. We believe that the CFO with the grant accountant and general ledger accountant should have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner so as to eliminate the risk of significant errors occurring. Budget-to-actual schedules should be an integral part of the grant accountant’s basic responsibilities. We further recommend that training be provided to all staff engaged in the financial reporting, allocation and reconciliation functions to ensure that a complete and accurate financial statements close-out process is achieved each month and annually. New policies and procedures should be established that conforms to the Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions: The management of Clayton County Community Services Authority, Inc. has reviewed the above referenced finding and fully agrees with the need for improved internal controls over financial statement preparation. Management believes that the proper approval of disbursements was adhered to during the reporting period with minimal deviation and continues to ensure proper policies are followed. Federal reports (SF425’s, LIHEAP) were filed during this period and may not have been properly reviewed during the course of this audit. For example, the LIHEAP reports were reconciled with the assistance of the State Program Specialist to ensure proper return of funds as requested by the funding agency. Management reserves the right to discuss this further as needed for the purpose of this finding. Adequate fiscal personnel staff has continued to be a challenge for the agency as management has done an exhaustive search for additional fiscal personnel and made job offers to qualified individuals only to have them decline the offer at the last moment. We have just offered the position of General Ledger Accountant to an individual and they are expected to start in two weeks. This will assist the CFO in the area of financial controls and reporting. It should also be noted that all bank reconciliations are current and being completed in a timely manner as dictated by our policies and procedures. Management continues to ensure all federal, state, and local and local regulatory reports and completed and submitted in a timely manner. As stated previously, the CFO worked directly with the State LIHEAP Program Staff to ensure proper reporting and reconciliation before returning unused funds.
CLAYTON COUNTY COMMUNITY SERVICES AUTHORITY, INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS Financial Statement Findings and Questioned Costs June 30, 2021 Comment #2021-001 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, PROPER APPROVAL OF DISBURSEMENTS, GRANT CLOSE-OUT PROCEDURES AND REQUIRED REGULATORY REPORTING POLICIES AND PROCEDURES SHOULD IMPROVED GENERAL (Repeat Finding) As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Authority. The preparation of these financial statements in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards state in summary, that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The closeout process is designed to help to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity of the current staff does not allow for adequate analysis of grants and contracts, other internal shared costs and support services provided, grantor receivables, deferred revenue, allocation of indirect costs and the reconciliation of bank accounts accurately and in a timely manner. Various regulatory reports were not filed accurately and in a timely manner (i.e., SF-425's for the Head Start Programs and DHS’s State budget reports for the LIHEAP programs). Specifically, revenue was recorded in excess of expenditures for the LIHEAP programs. Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually), which is consistent with our audit findings for the year ended June 30, 2020. The systemic cause appears to be a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of accounting controls, monitoring and policies and procedures not followed consistently. Context: Review of internal control structure of the organization in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§200.327 Financial reporting and 200.328 Monitoring and reporting program performance. [2 CFR §200.302(b)(2)] Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes. Cause: Limited personnel with knowledge and/or the ability to assist and provide needed information to aid in financial statement preparation. The implementation of a new accounting system without an adequate close-out of the old system. Recommendation: The degree to which the preparation of the financial statements and related disclosures are prepared by the independent auditor is a control deficiency is determined by the knowledge, skills and experience of those in the organization who are charged with the responsibility of its financial reporting. The Authority has a chief financial officer (CFO) and should hire additional staff (grant accountant and a general ledger accountant) to assist the new fiscal officer. The workload on the CFO is overwhelming. New staff hired should have the adequate skills, knowledge and experience to oversee and/or perform the necessary accounting functions each month. We believe that the CFO with the grant accountant and general ledger accountant should have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner so as to eliminate the risk of significant errors occurring. Budget-to-actual schedules should be an integral part of the grant accountant’s basic responsibilities. We further recommend that training be provided to all staff engaged in the financial reporting, allocation and reconciliation functions to ensure that a complete and accurate financial statements close-out process is achieved each month and annually. New policies and procedures should be established that conforms to the Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions: The management of Clayton County Community Services Authority, Inc. has reviewed the above referenced finding and fully agrees with the need for improved internal controls over financial statement preparation. Management believes that the proper approval of disbursements was adhered to during the reporting period with minimal deviation and continues to ensure proper policies are followed. Federal reports (SF425’s, LIHEAP) were filed during this period and may not have been properly reviewed during the course of this audit. For example, the LIHEAP reports were reconciled with the assistance of the State Program Specialist to ensure proper return of funds as requested by the funding agency. Management reserves the right to discuss this further as needed for the purpose of this finding. Adequate fiscal personnel staff has continued to be a challenge for the agency as management has done an exhaustive search for additional fiscal personnel and made job offers to qualified individuals only to have them decline the offer at the last moment. We have just offered the position of General Ledger Accountant to an individual and they are expected to start in two weeks. This will assist the CFO in the area of financial controls and reporting. It should also be noted that all bank reconciliations are current and being completed in a timely manner as dictated by our policies and procedures. Management continues to ensure all federal, state, and local and local regulatory reports and completed and submitted in a timely manner. As stated previously, the CFO worked directly with the State LIHEAP Program Staff to ensure proper reporting and reconciliation before returning unused funds.
CLAYTON COUNTY COMMUNITY SERVICES AUTHORITY, INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS Financial Statement Findings and Questioned Costs June 30, 2021 Comment #2021-001 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, PROPER APPROVAL OF DISBURSEMENTS, GRANT CLOSE-OUT PROCEDURES AND REQUIRED REGULATORY REPORTING POLICIES AND PROCEDURES SHOULD IMPROVED GENERAL (Repeat Finding) As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Authority. The preparation of these financial statements in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards state in summary, that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The closeout process is designed to help to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity of the current staff does not allow for adequate analysis of grants and contracts, other internal shared costs and support services provided, grantor receivables, deferred revenue, allocation of indirect costs and the reconciliation of bank accounts accurately and in a timely manner. Various regulatory reports were not filed accurately and in a timely manner (i.e., SF-425's for the Head Start Programs and DHS’s State budget reports for the LIHEAP programs). Specifically, revenue was recorded in excess of expenditures for the LIHEAP programs. Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually), which is consistent with our audit findings for the year ended June 30, 2020. The systemic cause appears to be a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of accounting controls, monitoring and policies and procedures not followed consistently. Context: Review of internal control structure of the organization in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§200.327 Financial reporting and 200.328 Monitoring and reporting program performance. [2 CFR §200.302(b)(2)] Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes. Cause: Limited personnel with knowledge and/or the ability to assist and provide needed information to aid in financial statement preparation. The implementation of a new accounting system without an adequate close-out of the old system. Recommendation: The degree to which the preparation of the financial statements and related disclosures are prepared by the independent auditor is a control deficiency is determined by the knowledge, skills and experience of those in the organization who are charged with the responsibility of its financial reporting. The Authority has a chief financial officer (CFO) and should hire additional staff (grant accountant and a general ledger accountant) to assist the new fiscal officer. The workload on the CFO is overwhelming. New staff hired should have the adequate skills, knowledge and experience to oversee and/or perform the necessary accounting functions each month. We believe that the CFO with the grant accountant and general ledger accountant should have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner so as to eliminate the risk of significant errors occurring. Budget-to-actual schedules should be an integral part of the grant accountant’s basic responsibilities. We further recommend that training be provided to all staff engaged in the financial reporting, allocation and reconciliation functions to ensure that a complete and accurate financial statements close-out process is achieved each month and annually. New policies and procedures should be established that conforms to the Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions: The management of Clayton County Community Services Authority, Inc. has reviewed the above referenced finding and fully agrees with the need for improved internal controls over financial statement preparation. Management believes that the proper approval of disbursements was adhered to during the reporting period with minimal deviation and continues to ensure proper policies are followed. Federal reports (SF425’s, LIHEAP) were filed during this period and may not have been properly reviewed during the course of this audit. For example, the LIHEAP reports were reconciled with the assistance of the State Program Specialist to ensure proper return of funds as requested by the funding agency. Management reserves the right to discuss this further as needed for the purpose of this finding. Adequate fiscal personnel staff has continued to be a challenge for the agency as management has done an exhaustive search for additional fiscal personnel and made job offers to qualified individuals only to have them decline the offer at the last moment. We have just offered the position of General Ledger Accountant to an individual and they are expected to start in two weeks. This will assist the CFO in the area of financial controls and reporting. It should also be noted that all bank reconciliations are current and being completed in a timely manner as dictated by our policies and procedures. Management continues to ensure all federal, state, and local and local regulatory reports and completed and submitted in a timely manner. As stated previously, the CFO worked directly with the State LIHEAP Program Staff to ensure proper reporting and reconciliation before returning unused funds.
Criteria 2 CFR Part 200, Section 302 and 45 CFR Part 75, Section 302- Financial management and standards for financial management systems state 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 own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award, (b) The financial management system of each non- Federal entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§200.327 Financial reporting and 200.328 Monitoring and reporting program performance. (3) Records that identifies adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income, and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets, and (5) Comparison of expenditures with budget amounts for each Federal award. Act Number 230 of July 23, 1974, Puerto Rico Government Accounting Law, as amended, states that the accounting system of the instrumentalities of the Commonwealth of Puerto Rico should be designed to reflect or provide complete and clear information related to their financial results of operations. Condition The Department has a weakened financial reporting system, brought on by several deficiencies related to the accounting and financial reporting practices of the Department. The deficiencies noted as part of our procedures are summarized as follows: • The Department's procedure manuals contain outdated procedures which do not necessarily reflect the current tasks and operations of the Department. • The Department does not prepare monthly closings on a recurring and periodic basis. • The Single Audit Report has not been submitted in a timely manner and audit procedures are significantly delayed due to a lack of reconciliations and monthly closing procedures. • Multiple transactions are recognized retroactively several months after occurring, as a result of the significant delays brought forth by a weak financial reporting system. • The Department does not have adequate procedures to reconcile, in a timely manner, financial transactions recorded in the accounting system of the Puerto Rico Treasury Department with the accounting records maintained by the Department. Effect Deficiencies in the financial reporting and accounting practices of the Department may result in the following: • Financial Reports which are required as part of compliance with federal programs may be prepared with inaccurate or incomplete financial information and may not be submitted in a timely and compliant manner. • Sanctions, reduced funding, return of monies to federal agencies, cancellation of grants, among other potential sanctions. • Inconsistency between the financial information registered in the Department with financial transactions recognized in the records of the Puerto Rico Treasury Department. • Difficulties in accurately assessing program performance and monitoring of expenses in line with budgeted amounts to actual amounts expended as part of program activities. Inefficiencies and additional effort incurred by employee's part as a result of outdated or inaccurate procedure manuals. This also results in confusion as to the proper procedures to follow and the relevant approval and revision tasks to be performed. • Non-compliance with federal program requirements brought forth as a result of financial information which is inaccurate. Cause The Department has not implemented a uniform internal accounting process that allows all the Department's administrations (5) to consolidate accounting information for both fiscal and program periods and reconcile with financial information with the Treasury Department. In addition, the Department lacks uniform internal accounting software and applications between the administrations of the Department, which precludes them from timely and accurate consolidation of financial information. Recommendation The Department needs to implement a formal monthly closing of its accounting records and financial reporting with the purpose of ensuring accurate and timely financial information. Monthly closing procedures would be carried out most efficiently by developing a logical order for closing procedures and assigning responsibility for completing the procedures to specific personnel. As the Department is composed of various administrations, a task force should be assigned to develop procedures which detail the data-gathering information process to accumulate financial data of the administrations in a consistent manner. In addition, financial information should be consolidated at the Department level in order to reconcile with the financial records of the Treasury Department. Procedures should include, at a minimum, the following: the month-end period, a list of monthly closing tasks (post sub ledger balances to general ledgers, post journal entries, reconcile financial records with those of the Treasury Department, etc.), and the due date of each task (2 weeks after month end, etc.) It is recommended that the closing and reconciliation procedures be documented in a checklist that indicates the responsible individual who will perform each procedure and when completion of each procedure is due. Following are recommendations regarding the required closing procedures and suggestions to improve the financial reporting system: • Determine that all transactions have been recorded and posted. Transactions should be reviewed for completeness by scanning accounts to determine any unusual balances or fluctuations from expectations. • Reconcile general ledger accounts to underlying records and compareireconcile this information with the records of the Puerto Rico Treasury Department. Any differences observed during this process should be followed up in a timely manner in order to clarify and clear any reconciling items between the two sets of financial records. • Accumulate pertinent information necessary for the preparation of federal reports (financial and performance reports). In addition, a proper flowchart of procedures and revisions should be prepared to ensure that federal reports are filed and certified within established deadlines. • Perform a budgetary analysis by comparing expected amounts of expenditure with actual results. This will provide a more accurate measure of performance for federal programs and the overall efficiency in the use of funds of the Department. This will enhance the monitoring of program performance to ensure compliance with federal regulations and State Plan objectives. • Proper storage and backup of Department data files as part of the closing procedure. All files should be properly backed up before monthly closing is determined to be complete. • Differences observed during the reconciliation and closing procedure need to be discussed with the management personnel responsible for providing oversight over each respective area of the financial reporting cycle. Any adjustments necessary as a result of these procedures should be posted in a timely manner and before the closing is completed. Internal control manuals should be evaluated to ensure that they provide a clear and descriptive flowchart which details personnel involved, flow of information, estimated time frames for deliverables, and other control procedures relevant to the Department's operations. The Department should also evaluate its existing manuals to determine if they are updated and accurately reflect the procedures the Department currently carries out and ensure that these are in compliance with federal requirements. Updated written procedures and instructions will prevent or reduce misunderstandings, errors, inefficiencies or wasted efforts, enhancing the efficiency of the operations of the Department. Questioned Costs None Management's Response Refer to Grantee's Corrective Action Plan.
Criteria 2 CFR Part 200, Section 302 and 45 CFR Part 75, Section 302- Financial management and standards for financial management systems state 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 own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award, (b) The financial management system of each non- Federal entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§200.327 Financial reporting and 200.328 Monitoring and reporting program performance. (3) Records that identifies adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income, and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets, and (5) Comparison of expenditures with budget amounts for each Federal award. Act Number 230 of July 23, 1974, Puerto Rico Government Accounting Law, as amended, states that the accounting system of the instrumentalities of the Commonwealth of Puerto Rico should be designed to reflect or provide complete and clear information related to their financial results of operations. Condition The Department has a weakened financial reporting system, brought on by several deficiencies related to the accounting and financial reporting practices of the Department. The deficiencies noted as part of our procedures are summarized as follows: • The Department's procedure manuals contain outdated procedures which do not necessarily reflect the current tasks and operations of the Department. • The Department does not prepare monthly closings on a recurring and periodic basis. • The Single Audit Report has not been submitted in a timely manner and audit procedures are significantly delayed due to a lack of reconciliations and monthly closing procedures. • Multiple transactions are recognized retroactively several months after occurring, as a result of the significant delays brought forth by a weak financial reporting system. • The Department does not have adequate procedures to reconcile, in a timely manner, financial transactions recorded in the accounting system of the Puerto Rico Treasury Department with the accounting records maintained by the Department. Effect Deficiencies in the financial reporting and accounting practices of the Department may result in the following: • Financial Reports which are required as part of compliance with federal programs may be prepared with inaccurate or incomplete financial information and may not be submitted in a timely and compliant manner. • Sanctions, reduced funding, return of monies to federal agencies, cancellation of grants, among other potential sanctions. • Inconsistency between the financial information registered in the Department with financial transactions recognized in the records of the Puerto Rico Treasury Department. • Difficulties in accurately assessing program performance and monitoring of expenses in line with budgeted amounts to actual amounts expended as part of program activities. Inefficiencies and additional effort incurred by employee's part as a result of outdated or inaccurate procedure manuals. This also results in confusion as to the proper procedures to follow and the relevant approval and revision tasks to be performed. • Non-compliance with federal program requirements brought forth as a result of financial information which is inaccurate. Cause The Department has not implemented a uniform internal accounting process that allows all the Department's administrations (5) to consolidate accounting information for both fiscal and program periods and reconcile with financial information with the Treasury Department. In addition, the Department lacks uniform internal accounting software and applications between the administrations of the Department, which precludes them from timely and accurate consolidation of financial information. Recommendation The Department needs to implement a formal monthly closing of its accounting records and financial reporting with the purpose of ensuring accurate and timely financial information. Monthly closing procedures would be carried out most efficiently by developing a logical order for closing procedures and assigning responsibility for completing the procedures to specific personnel. As the Department is composed of various administrations, a task force should be assigned to develop procedures which detail the data-gathering information process to accumulate financial data of the administrations in a consistent manner. In addition, financial information should be consolidated at the Department level in order to reconcile with the financial records of the Treasury Department. Procedures should include, at a minimum, the following: the month-end period, a list of monthly closing tasks (post sub ledger balances to general ledgers, post journal entries, reconcile financial records with those of the Treasury Department, etc.), and the due date of each task (2 weeks after month end, etc.) It is recommended that the closing and reconciliation procedures be documented in a checklist that indicates the responsible individual who will perform each procedure and when completion of each procedure is due. Following are recommendations regarding the required closing procedures and suggestions to improve the financial reporting system: • Determine that all transactions have been recorded and posted. Transactions should be reviewed for completeness by scanning accounts to determine any unusual balances or fluctuations from expectations. • Reconcile general ledger accounts to underlying records and compareireconcile this information with the records of the Puerto Rico Treasury Department. Any differences observed during this process should be followed up in a timely manner in order to clarify and clear any reconciling items between the two sets of financial records. • Accumulate pertinent information necessary for the preparation of federal reports (financial and performance reports). In addition, a proper flowchart of procedures and revisions should be prepared to ensure that federal reports are filed and certified within established deadlines. • Perform a budgetary analysis by comparing expected amounts of expenditure with actual results. This will provide a more accurate measure of performance for federal programs and the overall efficiency in the use of funds of the Department. This will enhance the monitoring of program performance to ensure compliance with federal regulations and State Plan objectives. • Proper storage and backup of Department data files as part of the closing procedure. All files should be properly backed up before monthly closing is determined to be complete. • Differences observed during the reconciliation and closing procedure need to be discussed with the management personnel responsible for providing oversight over each respective area of the financial reporting cycle. Any adjustments necessary as a result of these procedures should be posted in a timely manner and before the closing is completed. Internal control manuals should be evaluated to ensure that they provide a clear and descriptive flowchart which details personnel involved, flow of information, estimated time frames for deliverables, and other control procedures relevant to the Department's operations. The Department should also evaluate its existing manuals to determine if they are updated and accurately reflect the procedures the Department currently carries out and ensure that these are in compliance with federal requirements. Updated written procedures and instructions will prevent or reduce misunderstandings, errors, inefficiencies or wasted efforts, enhancing the efficiency of the operations of the Department. Questioned Costs None Management's Response Refer to Grantee's Corrective Action Plan.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
Reporting - Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2020-004) Criteria: Per CFR Section 200.328, nonfederal entities may be required to submit performance reports at least annually as required by the terms of the federal award. The Title III program requires annual performance reports which includes a section on expenditures incurred during the reporting period. Condition: The College did not submit annual performance reports on time. Cause: The College did not have sufficient procedures in place to ensure that the annual performance report is completed on time. Effect: The performance report was submitted after the required time. Questioned Costs: None Context: The annual performance report was requested for the program and the report that was provided covered October 1, 2020 to September 30, 2021, and was not submitted until January 2024. Recommendation: The College should ensure that all grant reports are prepared in a timely manner and should be submitte prior to the due date. View of Responsible Officials: The College will ensure that all grant reports are reviewed in detaiul and information reported will be traced to the source reports by the reviewer. The College also implemented policies and procedures to ensure all grant reports are submitted prior to the due date.
Reporting - Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2020-004) Criteria: Per CFR Section 200.328, nonfederal entities may be required to submit performance reports at least annually as required by the terms of the federal award. The Title III program requires annual performance reports which includes a section on expenditures incurred during the reporting period. Condition: The College did not submit annual performance reports on time. Cause: The College did not have sufficient procedures in place to ensure that the annual performance report is completed on time. Effect: The performance report was submitted after the required time. Questioned Costs: None Context: The annual performance report was requested for the program and the report that was provided covered October 1, 2020 to September 30, 2021, and was not submitted until January 2024. Recommendation: The College should ensure that all grant reports are prepared in a timely manner and should be submitte prior to the due date. View of Responsible Officials: The College will ensure that all grant reports are reviewed in detaiul and information reported will be traced to the source reports by the reviewer. The College also implemented policies and procedures to ensure all grant reports are submitted prior to the due date.
Condition: The Bureau lacks adequate financial management processes to produce timely, accurate, and complete financial information required for the Statement, SEFA, and federal reporting, including incomplete subsidiary records, delayed reconciliations, and insufficient program-level reporting. Criteria: 2 CFR 200.302 and 200.328 require accurate, current, and complete financial reporting and timely submission of required reports. Cause: Insufficient internal controls, lack of monitoring, and inadequate coordination between fiscal and program staff. Effect: Delays in required federal reporting, errors in financial information, and noncompliance with Uniform Guidance deadlines, increasing the risk of unreliable reporting. Questioned Costs: None. Context: The condition has affected multiple audit cycles but was not reported as a finding in the prior year’s final audit. Recommendation: Strengthen internal controls over financial management, improve subsidiary records and reconciliations, implement a formal reporting calendar, enhance coordination among staff, and provide training on PRIFAS, UG requirements, and reporting procedures to ensure accurate and timely reporting.
Condition: The Bureau did not provide evidence of having prepared or submitted the required quarterly Federal Financial Reports (SF-425) or equivalent COR3 financial status reports for FEMA Public Assistance Program ALN 97.036; despite repeated audit requests, no SF-425s or alternative reports demonstrating cumulative expenditures, federal share, or matching funds were made available, and therefore compliance with federal and pass-through reporting requirements could not be verified. Criteria: Under 2 CFR 200.328(a) and 200.302(b)(5), recipients and subrecipients must submit accurate, complete, and timely financial reports as prescribed by the awarding agency, including quarterly SF-425 (or COR3) reports; reporting deadlines for SF-425s are generally January 30, April 30, July 30, and October 30. Context: During the audit, the Bureau did not provide SF-425 reports for FEMA grants, preventing the auditors from verifying whether reports were prepared, submitted timely, or reconciled to PRIFAS accounting records; similar deficiencies were identified in prior audits (Findings 2016-03, 2019-06, and 2020-05), indicating the condition remains uncorrected and systemic. Cause: The Bureau lacks effective internal controls assigning responsibility for preparing, reviewing, and submitting SF-425 or COR3 financial reports, and there is no monitoring mechanism to ensure reports are completed and submitted by required due dates. Effect: Failure to prepare and submit required financial reports constitutes noncompliance with Uniform Guidance and FEMA/COR3 grant conditions, impedes grantor oversight of project progress and expenditure status, increases the risk of questioned costs or delayed reimbursements, and may result in sanctions such as suspension of funding or withholding of future obligations until reports are submitted and accepted. Recommendation: The Bureau should establish and enforce written procedures to ensure SF-425 or COR3 financial reports are prepared, reviewed, and submitted within prescribed deadlines, assign reporting responsibilities to specific personnel, implement a monitoring calendar to track compliance, and ensure reports are supported by reconciled accounting data from PRIFAS and other reporting systems. Questioned Costs: None. Management Response: See corrective action plan.
FINDING 2020-003 Subject: Water and Waste Disposal Systems for Rural Communities - Reporting Federal Agency: Department of Agriculture Federal Program: Water and Waste Disposal Systems for Rural Communities Assistance Listings Number: 10.760 Federal Award Number and Year (or Other Identifying Number): CY2020 Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context Annual financial reports are to be filed with the awarding agency. The Town was required to file two reports during the audit period, the Statement of Budget, Income and Equity (Form RD 442-2) and the Balance Sheet (Form RD 442-3) with the U.S. Department of Agriculture (USDA). The Form RD 442-2 covers financial operations relating to the Town's water main replacement project and the Form RD 442-3 presents the financial status of the project. In both instances, a borrower may submit the financial data on other forms, provided the forms are in a similar format and signed and dated by the organization's official to certify the correctness of the information. Alternatively, an annual audit may be submitted in lieu of the forms. The Town did not prepare or file the required reports, submit financial data on other forms, or submit an annual audit in lieu of the forms to the USDA. As such, we could not substantiate the financial operations or the financial status of the project. Additionally, the Town did not obtain a written waiver from the USDA to allow the Town not to file the reports. The lack of internal controls and noncompliance were systemic issues, which occurred throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 TOWN OF MONROEVILLE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 7 CFR 1780.47(e) states: "Borrowers exempt from audits. All borrowers who are exempt from audits, will, within 60 days following the end of each fiscal year, furnish the RUS with annual financial statements, consisting of a verification of the organization's balance sheet and statement of income and expense by an appropriate official of the organization. Forms RD 442-2, 'Statement of Budget, Income and Equity,' and 442-3 may be used." Cause Management of the Town had not established an effective system of internal controls that segregated key functions and would have ensured compliance with reporting requirements of the grant. As a result, Form 442-2 and Form 442-3 were not filed. The Town did not obtain a written waiver from the USDA to support the reports not being filed. Effect Without the proper implementation of an effectively designed system of internal controls, the Town cannot ensure the required reports were filed with the awarding agency. As such, the USDA does not have accurate and current information to discern the financial status of the Town's project. Furthermore, noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the Town. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Town's management establish a proper system of internal controls and develop policies and procedures to ensure required reports, or allowable alternatives, are completed and filed with the USDA. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2020-003 Subject: Water and Waste Disposal Systems for Rural Communities - Reporting Federal Agency: Department of Agriculture Federal Program: Water and Waste Disposal Systems for Rural Communities Assistance Listings Number: 10.760 Federal Award Number and Year (or Other Identifying Number): CY2020 Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context Annual financial reports are to be filed with the awarding agency. The Town was required to file two reports during the audit period, the Statement of Budget, Income and Equity (Form RD 442-2) and the Balance Sheet (Form RD 442-3) with the U.S. Department of Agriculture (USDA). The Form RD 442-2 covers financial operations relating to the Town's water main replacement project and the Form RD 442-3 presents the financial status of the project. In both instances, a borrower may submit the financial data on other forms, provided the forms are in a similar format and signed and dated by the organization's official to certify the correctness of the information. Alternatively, an annual audit may be submitted in lieu of the forms. The Town did not prepare or file the required reports, submit financial data on other forms, or submit an annual audit in lieu of the forms to the USDA. As such, we could not substantiate the financial operations or the financial status of the project. Additionally, the Town did not obtain a written waiver from the USDA to allow the Town not to file the reports. The lack of internal controls and noncompliance were systemic issues, which occurred throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 TOWN OF MONROEVILLE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 7 CFR 1780.47(e) states: "Borrowers exempt from audits. All borrowers who are exempt from audits, will, within 60 days following the end of each fiscal year, furnish the RUS with annual financial statements, consisting of a verification of the organization's balance sheet and statement of income and expense by an appropriate official of the organization. Forms RD 442-2, 'Statement of Budget, Income and Equity,' and 442-3 may be used." Cause Management of the Town had not established an effective system of internal controls that segregated key functions and would have ensured compliance with reporting requirements of the grant. As a result, Form 442-2 and Form 442-3 were not filed. The Town did not obtain a written waiver from the USDA to support the reports not being filed. Effect Without the proper implementation of an effectively designed system of internal controls, the Town cannot ensure the required reports were filed with the awarding agency. As such, the USDA does not have accurate and current information to discern the financial status of the Town's project. Furthermore, noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the Town. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Town's management establish a proper system of internal controls and develop policies and procedures to ensure required reports, or allowable alternatives, are completed and filed with the USDA. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2020-104 Lack of Documentation Related to Reporting and Lack of Controls Related to Filing Reports (prior two years 2019-106 and 2018-009) (initially reported 2018) Assistance Listing Number: 93.224 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: 6H80CS06452-15 (2020), COVID-19 1H8CCS35035-01 (2020), COVID-19 1H8DCS36007-01 (2020) and COVID-19 1H8ECS39010-01 (2020) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements and there was no review of the reports prior to submission to the grantor, other than the review done by the preparer. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: The Organization has considered a third-party review after initial submission a sufficient internal control for the UDS report, and did not consider it necessary on the SF-425 due to the limited information required. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its reporting policy and implemented the changes. The corrective action for this finding has been approved and implemented by the Organization.
2020-104 Lack of Documentation Related to Reporting and Lack of Controls Related to Filing Reports (prior two years 2019-106 and 2018-009) (initially reported 2018) Assistance Listing Number: 93.224 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: 6H80CS06452-15 (2020), COVID-19 1H8CCS35035-01 (2020), COVID-19 1H8DCS36007-01 (2020) and COVID-19 1H8ECS39010-01 (2020) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements and there was no review of the reports prior to submission to the grantor, other than the review done by the preparer. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: The Organization has considered a third-party review after initial submission a sufficient internal control for the UDS report, and did not consider it necessary on the SF-425 due to the limited information required. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its reporting policy and implemented the changes. The corrective action for this finding has been approved and implemented by the Organization.
2020-104 Lack of Documentation Related to Reporting and Lack of Controls Related to Filing Reports (prior two years 2019-106 and 2018-009) (initially reported 2018) Assistance Listing Number: 93.224 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: 6H80CS06452-15 (2020), COVID-19 1H8CCS35035-01 (2020), COVID-19 1H8DCS36007-01 (2020) and COVID-19 1H8ECS39010-01 (2020) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements and there was no review of the reports prior to submission to the grantor, other than the review done by the preparer. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: The Organization has considered a third-party review after initial submission a sufficient internal control for the UDS report, and did not consider it necessary on the SF-425 due to the limited information required. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its reporting policy and implemented the changes. The corrective action for this finding has been approved and implemented by the Organization.
2020-104 Lack of Documentation Related to Reporting and Lack of Controls Related to Filing Reports (prior two years 2019-106 and 2018-009) (initially reported 2018) Assistance Listing Number: 93.224 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: 6H80CS06452-15 (2020), COVID-19 1H8CCS35035-01 (2020), COVID-19 1H8DCS36007-01 (2020) and COVID-19 1H8ECS39010-01 (2020) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements and there was no review of the reports prior to submission to the grantor, other than the review done by the preparer. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: The Organization has considered a third-party review after initial submission a sufficient internal control for the UDS report, and did not consider it necessary on the SF-425 due to the limited information required. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its reporting policy and implemented the changes. The corrective action for this finding has been approved and implemented by the Organization.
2020-104 Lack of Documentation Related to Reporting and Lack of Controls Related to Filing Reports (prior two years 2019-106 and 2018-009) (initially reported 2018) Assistance Listing Number: 93.224 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: 6H80CS06452-15 (2020), COVID-19 1H8CCS35035-01 (2020), COVID-19 1H8DCS36007-01 (2020) and COVID-19 1H8ECS39010-01 (2020) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements and there was no review of the reports prior to submission to the grantor, other than the review done by the preparer. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: The Organization has considered a third-party review after initial submission a sufficient internal control for the UDS report, and did not consider it necessary on the SF-425 due to the limited information required. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its reporting policy and implemented the changes. The corrective action for this finding has been approved and implemented by the Organization.
2020-104 Lack of Documentation Related to Reporting and Lack of Controls Related to Filing Reports (prior two years 2019-106 and 2018-009) (initially reported 2018) Assistance Listing Number: 93.224 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: 6H80CS06452-15 (2020), COVID-19 1H8CCS35035-01 (2020), COVID-19 1H8DCS36007-01 (2020) and COVID-19 1H8ECS39010-01 (2020) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements and there was no review of the reports prior to submission to the grantor, other than the review done by the preparer. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: The Organization has considered a third-party review after initial submission a sufficient internal control for the UDS report, and did not consider it necessary on the SF-425 due to the limited information required. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its reporting policy and implemented the changes. The corrective action for this finding has been approved and implemented by the Organization.
2020-104 Lack of Documentation Related to Reporting and Lack of Controls Related to Filing Reports (prior two years 2019-106 and 2018-009) (initially reported 2018) Assistance Listing Number: 93.224 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: 6H80CS06452-15 (2020), COVID-19 1H8CCS35035-01 (2020), COVID-19 1H8DCS36007-01 (2020) and COVID-19 1H8ECS39010-01 (2020) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements and there was no review of the reports prior to submission to the grantor, other than the review done by the preparer. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: The Organization has considered a third-party review after initial submission a sufficient internal control for the UDS report, and did not consider it necessary on the SF-425 due to the limited information required. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its reporting policy and implemented the changes. The corrective action for this finding has been approved and implemented by the Organization.
2020-104 Lack of Documentation Related to Reporting and Lack of Controls Related to Filing Reports (prior two years 2019-106 and 2018-009) (initially reported 2018) Assistance Listing Number: 93.224 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: 6H80CS06452-15 (2020), COVID-19 1H8CCS35035-01 (2020), COVID-19 1H8DCS36007-01 (2020) and COVID-19 1H8ECS39010-01 (2020) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements and there was no review of the reports prior to submission to the grantor, other than the review done by the preparer. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: The Organization has considered a third-party review after initial submission a sufficient internal control for the UDS report, and did not consider it necessary on the SF-425 due to the limited information required. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its reporting policy and implemented the changes. The corrective action for this finding has been approved and implemented by the Organization.
Finding Number: 2020-003 Agency: Department of Homeland Security Federal Program: DISASTER GRANTS - PUBLIC ASSISTANCE (Presidentially Declared Disasters) Assistant listing number: 97.036 Grant Number: All grants in SEFA Grant Period: July 1, 2018 through June 30, 2020 Compliance Requirement: Reporting Category: Significant Deficiency Criteria: As per § 200.328 Financial reporting. Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. Condition: During the audit, we note differences between quarterly reports amounts submitted to grantee agency and expense amounts accrued during the year. Grant Report (Name) PW Number Date submitted Deadline Extension date approved Report submitted on time? Yes/No Expenditures as per QPR Expenditures as per SEFA FEMA 1798-DR-PR Proyecto Completado PW-4339-430 6/30/2020 7/30/2020 No Yes - 1,710,856 FEMA 1798-DR-PR Proyecto sin comenzar PW-4339-1335 6/30/2020 7/30/2020 NO Yes - 532,350 Cause: Missing of supporting documentation and underlying data support reporting figures amount. Effect: Wrong reported amounts could significantly affect program outcomes. Recommendation: To keep, document, file and trace supporting data for to support quarterly reports Questioned Costs: None Perspective of the information: The information was not drawn from a statistical sample. Prior Year Finding: No Management response: A specialized federal funds firm was hired. It is working with internal controls to improve the method of accounting for federal funds that meet accounting and FEMA requirements. Responsible Official: Mr. José R. González de la Vega Estimated Completion Date: To complete on or before December 2023
Finding Number: 2020-003 Agency: Department of Homeland Security Federal Program: DISASTER GRANTS - PUBLIC ASSISTANCE (Presidentially Declared Disasters) Assistant listing number: 97.036 Grant Number: All grants in SEFA Grant Period: July 1, 2018 through June 30, 2020 Compliance Requirement: Reporting Category: Significant Deficiency Criteria: As per § 200.328 Financial reporting. Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. Condition: During the audit, we note differences between quarterly reports amounts submitted to grantee agency and expense amounts accrued during the year. Grant Report (Name) PW Number Date submitted Deadline Extension date approved Report submitted on time? Yes/No Expenditures as per QPR Expenditures as per SEFA FEMA 1798-DR-PR Proyecto Completado PW-4339-430 6/30/2020 7/30/2020 No Yes - 1,710,856 FEMA 1798-DR-PR Proyecto sin comenzar PW-4339-1335 6/30/2020 7/30/2020 NO Yes - 532,350 Cause: Missing of supporting documentation and underlying data support reporting figures amount. Effect: Wrong reported amounts could significantly affect program outcomes. Recommendation: To keep, document, file and trace supporting data for to support quarterly reports Questioned Costs: None Perspective of the information: The information was not drawn from a statistical sample. Prior Year Finding: No Management response: A specialized federal funds firm was hired. It is working with internal controls to improve the method of accounting for federal funds that meet accounting and FEMA requirements. Responsible Official: Mr. José R. González de la Vega Estimated Completion Date: To complete on or before December 2023
I NOTED THAT ALL OF THE REQUIRED QUARTERLY AND NARRATIVE REPORTS WERE NOT FILED OR RETAINED FOR THE BIA 638 GRANT. I ALSO NOTED THAT THE ANNUAL APR HUD REPORT AS WELL AS THE QUARTERLY425 HUD REPORTS DID NOT APPEAR TO BE FILED TIMELY. PER 2CFR SECTION 200.328 AND 329 THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS. NO QUESTIONED COSTS. I WAS NOT ABLE TO REVIEW THE 4 QUARTERLY REPORTS FOR THE BIA 638 GRANTS. I NOTED THAT THE 4 QUARTERLY REPORTS AND THE ANNUAL APR FOR THE HUD IHBG GRANT WERE FILED BUT NOT DONE TIMELY.
I NOTED THAT ALL OF THE REQUIRED QUARTERLY AND NARRATIVE REPORTS WERE NOT FILED OR RETAINED FOR THE BIA 638 GRANT. I ALSO NOTED THAT THE ANNUAL APR HUD REPORT AS WELL AS THE QUARTERLY425 HUD REPORTS DID NOT APPEAR TO BE FILED TIMELY. PER 2CFR SECTION 200.328 AND 329 THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS. NO QUESTIONED COSTS. I WAS NOT ABLE TO REVIEW THE 4 QUARTERLY REPORTS FOR THE BIA 638 GRANTS. I NOTED THAT THE 4 QUARTERLY REPORTS AND THE ANNUAL APR FOR THE HUD IHBG GRANT WERE FILED BUT NOT DONE TIMELY.
I NOTED THAT ALL OF THE REQUIRED QUARTERLY AND NARRATIVE REPORTS WERE NOT FILED OR RETAINED FOR THE BIA 638 GRANT. I ALSO NOTED THAT THE ANNUAL APR HUD REPORT AS WELL AS THE QUARTERLY425 HUD REPORTS DID NOT APPEAR TO BE FILED TIMELY. PER 2CFR SECTION 200.328 AND 329 THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS. NO QUESTIONED COSTS. I WAS NOT ABLE TO REVIEW THE 4 QUARTERLY REPORTS FOR THE BIA 638 GRANTS. I NOTED THAT THE 4 QUARTERLY REPORTS AND THE ANNUAL APR FOR THE HUD IHBG GRANT WERE FILED BUT NOT DONE TIMELY.
I NOTED THAT ALL OF THE REQUIRED QUARTERLY AND NARRATIVE REPORTS WERE NOT FILED OR RETAINED FOR THE BIA 638 GRANT. I ALSO NOTED THAT THE ANNUAL APR HUD REPORT AS WELL AS THE QUARTERLY425 HUD REPORTS DID NOT APPEAR TO BE FILED TIMELY. PER 2CFR SECTION 200.328 AND 329 THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS. NO QUESTIONED COSTS. I WAS NOT ABLE TO REVIEW THE 4 QUARTERLY REPORTS FOR THE BIA 638 GRANTS. I NOTED THAT THE 4 QUARTERLY REPORTS AND THE ANNUAL APR FOR THE HUD IHBG GRANT WERE FILED BUT NOT DONE TIMELY.
I NOTED THAT ALL OF THE REQUIRED QUARTERLY AND NARRATIVE REPORTS WERE NOT FILED OR RETAINED FOR THE BIA 638 GRANT. I ALSO NOTED THAT THE ANNUAL APR HUD REPORT AS WELL AS THE QUARTERLY425 HUD REPORTS DID NOT APPEAR TO BE FILED TIMELY. PER 2CFR SECTION 200.328 AND 329 THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS. NO QUESTIONED COSTS. I WAS NOT ABLE TO REVIEW THE 4 QUARTERLY REPORTS FOR THE BIA 638 GRANTS. I NOTED THAT THE 4 QUARTERLY REPORTS AND THE ANNUAL APR FOR THE HUD IHBG GRANT WERE FILED BUT NOT DONE TIMELY.
I NOTED THAT ALL OF THE REQUIRED QUARTERLY AND NARRATIVE REPORTS WERE NOT FILED OR RETAINED FOR THE BIA 638 GRANT. I ALSO NOTED THAT THE ANNUAL APR HUD REPORT AS WELL AS THE QUARTERLY425 HUD REPORTS DID NOT APPEAR TO BE FILED TIMELY. PER 2CFR SECTION 200.328 AND 329 THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS. NO QUESTIONED COSTS. I WAS NOT ABLE TO REVIEW THE 4 QUARTERLY REPORTS FOR THE BIA 638 GRANTS. I NOTED THAT THE 4 QUARTERLY REPORTS AND THE ANNUAL APR FOR THE HUD IHBG GRANT WERE FILED BUT NOT DONE TIMELY.
I NOTED THAT ALL OF THE REQUIRED QUARTERLY AND NARRATIVE REPORTS WERE NOT FILED OR RETAINED FOR THE BIA 638 GRANT. I ALSO NOTED THAT THE ANNUAL APR HUD REPORT AS WELL AS THE QUARTERLY425 HUD REPORTS DID NOT APPEAR TO BE FILED TIMELY. PER 2CFR SECTION 200.328 AND 329 THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS. NO QUESTIONED COSTS. I WAS NOT ABLE TO REVIEW THE 4 QUARTERLY REPORTS FOR THE BIA 638 GRANTS. I NOTED THAT THE 4 QUARTERLY REPORTS AND THE ANNUAL APR FOR THE HUD IHBG GRANT WERE FILED BUT NOT DONE TIMELY.
I NOTED THAT ALL OF THE REQUIRED QUARTERLY AND NARRATIVE REPORTS WERE NOT FILED OR RETAINED FOR THE BIA 638 GRANT. I ALSO NOTED THAT THE ANNUAL APR HUD REPORT AS WELL AS THE QUARTERLY425 HUD REPORTS DID NOT APPEAR TO BE FILED TIMELY. PER 2CFR SECTION 200.328 AND 329 THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS. NO QUESTIONED COSTS. I WAS NOT ABLE TO REVIEW THE 4 QUARTERLY REPORTS FOR THE BIA 638 GRANTS. I NOTED THAT THE 4 QUARTERLY REPORTS AND THE ANNUAL APR FOR THE HUD IHBG GRANT WERE FILED BUT NOT DONE TIMELY.
I NOTED THAT ALL OF THE REQUIRED FINANCIAL QUARTERLY AND NARRATIVE REPORTS WERE NOT FILED OR RETAINED BY THE BIA 638 GRANTS. PER 2 CFR, SECTION 200.328 AND 200.329, THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS, NO QUESTIONED COSTS, MANAGEMENT DID NOT HAVE CONTROLS IN PLACE TO ENSURE THAT ALL GRANT REPORTS WERE FILED TIMELY. I WAS NOT ABLE TO REVIEW THE 4 QUARTERLY FINANCIAL OR NARRATIVE REPORTS FOR THESE THREE GRANTS, THE COUNCIL IS DELINQUENT IN THE REPORTING FOR THESE GRANTS.
I NOTED THAT ALL OF THE REQUIRED FINANCIAL QUARTERLY AND NARRATIVE REPORTS WERE NOT FILED OR RETAINED BY THE BIA 638 GRANTS. PER 2 CFR, SECTION 200.328 AND 200.329, THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS, NO QUESTIONED COSTS, MANAGEMENT DID NOT HAVE CONTROLS IN PLACE TO ENSURE THAT ALL GRANT REPORTS WERE FILED TIMELY. I WAS NOT ABLE TO REVIEW THE 4 QUARTERLY FINANCIAL OR NARRATIVE REPORTS FOR THESE THREE GRANTS, THE COUNCIL IS DELINQUENT IN THE REPORTING FOR THESE GRANTS.
I NOTED THAT ALL OF THE REQUIRED FINANCIAL QUARTERLY AND NARRATIVE REPORTS WERE NOT FILED OR RETAINED BY THE BIA 638 GRANTS. PER 2 CFR, SECTION 200.328 AND 200.329, THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS, NO QUESTIONED COSTS, MANAGEMENT DID NOT HAVE CONTROLS IN PLACE TO ENSURE THAT ALL GRANT REPORTS WERE FILED TIMELY. I WAS NOT ABLE TO REVIEW THE 4 QUARTERLY FINANCIAL OR NARRATIVE REPORTS FOR THESE THREE GRANTS, THE COUNCIL IS DELINQUENT IN THE REPORTING FOR THESE GRANTS.
THE COUNCIL DID NOT SUBMIT THE REPORTING PACKAGE TIMELY IN ACCORDANCE WITH THE UNIFORM GUIDANCE REQUIREMENT OF SUBMITTING THE REPORTING PACKAGE WITHIN 9 MONTHS OF YEAR END. IN ADDITION, IT WAS NOTED THAT THE APR WAS FILED LATE. PER 2 CFR SECTION 200.328 AND 329, THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS. PER SECTION 200.501, THE COUNCIL MUST HAVE AN AUDIT PERFORMED WITHIN 9 MONTHS OF YEAR END. QUESTIONED COSTS NOT DETERMINED, MANAGEMENT DID NOT ENSURE THAT THAT THE AUIDT AND ALL REPORTS WERE FILED/SUBMITTED TIMELY
I NOTED THAT ALL OF THE REQUIRED FINANCIAL QUARTERLY AND NARRATIVE REPORTS WERE NOT FILED OR RETAINED BY THE BIA 638 GRANTS. PER 2 CFR, SECTION 200.328 AND 200.329, THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS, NO QUESTIONED COSTS, MANAGEMENT DID NOT HAVE CONTROLS IN PLACE TO ENSURE THAT ALL GRANT REPORTS WERE FILED TIMELY. I WAS NOT ABLE TO REVIEW THE 4 QUARTERLY FINANCIAL OR NARRATIVE REPORTS FOR THESE THREE GRANTS, THE COUNCIL IS DELINQUENT IN THE REPORTING FOR THESE GRANTS.
I NOTED THAT ALL OF THE REQUIRED FINANCIAL QUARTERLY AND NARRATIVE REPORTS WERE NOT FILED OR RETAINED BY THE BIA 638 GRANTS. PER 2 CFR, SECTION 200.328 AND 200.329, THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS, NO QUESTIONED COSTS, MANAGEMENT DID NOT HAVE CONTROLS IN PLACE TO ENSURE THAT ALL GRANT REPORTS WERE FILED TIMELY. I WAS NOT ABLE TO REVIEW THE 4 QUARTERLY FINANCIAL OR NARRATIVE REPORTS FOR THESE THREE GRANTS, THE COUNCIL IS DELINQUENT IN THE REPORTING FOR THESE GRANTS.
I NOTED THAT ALL OF THE REQUIRED FINANCIAL QUARTERLY AND NARRATIVE REPORTS WERE NOT FILED OR RETAINED BY THE BIA 638 GRANTS. PER 2 CFR, SECTION 200.328 AND 200.329, THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS, NO QUESTIONED COSTS, MANAGEMENT DID NOT HAVE CONTROLS IN PLACE TO ENSURE THAT ALL GRANT REPORTS WERE FILED TIMELY. I WAS NOT ABLE TO REVIEW THE 4 QUARTERLY FINANCIAL OR NARRATIVE REPORTS FOR THESE THREE GRANTS, THE COUNCIL IS DELINQUENT IN THE REPORTING FOR THESE GRANTS.
THE COUNCIL DID NOT SUBMIT THE REPORTING PACKAGE TIMELY IN ACCORDANCE WITH THE UNIFORM GUIDANCE REQUIREMENT OF SUBMITTING THE REPORTING PACKAGE WITHIN 9 MONTHS OF YEAR END. IN ADDITION, IT WAS NOTED THAT THE APR WAS FILED LATE. PER 2 CFR SECTION 200.328 AND 329, THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS. PER SECTION 200.501, THE COUNCIL MUST HAVE AN AUDIT PERFORMED WITHIN 9 MONTHS OF YEAR END. QUESTIONED COSTS NOT DETERMINED, MANAGEMENT DID NOT ENSURE THAT THAT THE AUIDT AND ALL REPORTS WERE FILED/SUBMITTED TIMELY