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