Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Federal Agency: Department of Education Federal Programs: COVID-19 – Education Stabilization Fund Assistance Listing Numbers: 84.425E, 84.425F, 84.425K Federal Award Identification Number and Year: P425E200449, P425F204781, P425K200022 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Funds (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: The College is not in compliance with Quarterly and Annual reporting requirements for HEERF. Questioned Costs: None. Context: Out of 2 Quarterly Institutional and 2 Quarterly Student reports tested all 4 reports were not submitted timely. In addition, the annual report was not submitted timely. Cause: The College did not have appropriate controls in place to ensure reports were completed and published to the institution’s website in a timely manner. Effect: The institution is not meeting the reporting and information-sharing requirements determined by the Department of Education. As a result, the institution may be subject to additional enforcement actions by the Department of Education including a delay in funding for additional HEERF programs and possibly being determined ineligible for other program funding. Repeat Finding: No. Recommendation: We recommend the College review the reporting requirements and implement procedures to ensure that all required reports are issued/posted in an accurate and timely manner. Views of Responsible Officials: Management agrees with the finding and has prepared a plan to correct the finding.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Criteria: Reporting ? Per 2 CFR Part 200.328 and 2CFR Part 200.329, institutions must publicly display on their website the total number of students who have received an Emergency Financial Aid Grant. Institutions are required to submit quarterly budget and expenditure reports detailing institutional expenditures of HEERF funds. Condition: The institution?s count of number of students who have received an Emergency Financial Aid Grant disclosed on the website is not accurate. A quarterly report for institutional portion expenditures was not submitted accurately. Questioned Costs: None. Context: Students eligible to receive an Emergency Financial Aid Grant were reported incorrectly. We received the listing of students used for the reporting disclosures and performed recounts. For the September 30, 2021 disbursement, the College reported 1,291 students received emergency funding instead of the actual number, 1,517, a difference of 226 students. Additionally, for the December 31, 2021 disbursement, the College reported 1,291 students received emergency funding instead of the actual number, 1,514, a difference of 223 students. Finally, the 4th quarter institutional share report inaccurately stated all disbursements were for lost revenues instead of $122,346 being allocated for COVID related expenses. Effect: The disclosures on the website are not accurate. Cause: Internal controls were not adequately designed and implemented to ensure compliance with the program?s reporting requirements. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend implementing controls to ensure the College complies with the programs reporting compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Administration concurs with the findings. The College has corrected the website disclosure of number of students receiving Aid Grants under the program. The College will review and confirm accuracy of any future report submissions. Anticipated Completion Date: May 31, 2023
Criteria: Reporting ? Per 2 CFR Part 200.328 and 2CFR Part 200.329, institutions must publicly display on their website the total number of students who have received an Emergency Financial Aid Grant. Institutions are required to submit quarterly budget and expenditure reports detailing institutional expenditures of HEERF funds. Condition: The institution?s count of number of students who have received an Emergency Financial Aid Grant disclosed on the website is not accurate. A quarterly report for institutional portion expenditures was not submitted accurately. Questioned Costs: None. Context: Students eligible to receive an Emergency Financial Aid Grant were reported incorrectly. We received the listing of students used for the reporting disclosures and performed recounts. For the September 30, 2021 disbursement, the College reported 1,291 students received emergency funding instead of the actual number, 1,517, a difference of 226 students. Additionally, for the December 31, 2021 disbursement, the College reported 1,291 students received emergency funding instead of the actual number, 1,514, a difference of 223 students. Finally, the 4th quarter institutional share report inaccurately stated all disbursements were for lost revenues instead of $122,346 being allocated for COVID related expenses. Effect: The disclosures on the website are not accurate. Cause: Internal controls were not adequately designed and implemented to ensure compliance with the program?s reporting requirements. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend implementing controls to ensure the College complies with the programs reporting compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Administration concurs with the findings. The College has corrected the website disclosure of number of students receiving Aid Grants under the program. The College will review and confirm accuracy of any future report submissions. Anticipated Completion Date: May 31, 2023
Finding 2022-001 ? Significant Deficiency: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds - Reporting Federal Program: COVID-19 Education Stabilization Fund Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number: 84.425E, 84.425F Federal Award Number: P425E200445 Federal Award Year: June 30, 2022 Criteria: Section 18004 of the Coronavirus Aid, Relief and Economic Security (CARES) ACT and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations (CRRSAA) Act directs institutions receiving funds to promptly and timely provide detailed accounting of the use and expenditures for HEERF (Higher Education Emergency Relief Funds) I, HEERF II, and HEERF III funds. Each institution is required to share in an easily accessible public location quarterly reports (September 30, December 31, March 31, June 30). The reporting is required for both the Student Portion and the Institutional Portion. While the American Rescue Plan (ARP) does not explicitly identify procedures by which institutions submit a report to the Secretary, the Department exercises this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Condition/Context: The College did not post the required quarterly reports for the Student Portion. Additionally, during the audit, it was noted that the College was unable to provide a copy of the annual report and supporting documentation for the year ended December 31, 2021. Cause: Staff turnover at the College was the primary factor leading to the issues noted above. Effect: The College did not provide the public and the Department with all required data related to HEERF and the Student Portion reports were not posted in a timely manner. Questioned Costs: Not applicable. Recommendation: The College should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management's Response: MCAD has experienced 100% turnover in the positions responsible for submitting the HEERF reporting. The internal data supporting these reports is accessible for future reporting to be done in a timely manner.
Finding 2022-001 ? Significant Deficiency: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds - Reporting Federal Program: COVID-19 Education Stabilization Fund Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number: 84.425E, 84.425F Federal Award Number: P425E200445 Federal Award Year: June 30, 2022 Criteria: Section 18004 of the Coronavirus Aid, Relief and Economic Security (CARES) ACT and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations (CRRSAA) Act directs institutions receiving funds to promptly and timely provide detailed accounting of the use and expenditures for HEERF (Higher Education Emergency Relief Funds) I, HEERF II, and HEERF III funds. Each institution is required to share in an easily accessible public location quarterly reports (September 30, December 31, March 31, June 30). The reporting is required for both the Student Portion and the Institutional Portion. While the American Rescue Plan (ARP) does not explicitly identify procedures by which institutions submit a report to the Secretary, the Department exercises this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Condition/Context: The College did not post the required quarterly reports for the Student Portion. Additionally, during the audit, it was noted that the College was unable to provide a copy of the annual report and supporting documentation for the year ended December 31, 2021. Cause: Staff turnover at the College was the primary factor leading to the issues noted above. Effect: The College did not provide the public and the Department with all required data related to HEERF and the Student Portion reports were not posted in a timely manner. Questioned Costs: Not applicable. Recommendation: The College should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management's Response: MCAD has experienced 100% turnover in the positions responsible for submitting the HEERF reporting. The internal data supporting these reports is accessible for future reporting to be done in a timely manner.
Finding 2022-001 Federal program: Education Stabilization Fund -Higher Education Emergency Relief Fund (HEERF): COVID-19 CARES Act- Student Aid Portion AL #: 84.425E Award Year: 2021/2022 Type of finding: Deficiency and Noncompliance Compliance requirement: Reporting - Special Reporting Criteria: Under 2 CFR 200.328 and 200.329, Universities must publicly post certain information relating to Student Aid awards on their website no later than 30 days after award, and update that information within 10 days after the end of every calendar quarter by posting a new report. Condition: Due to the timing of the prior year finding being identified, the award notification report, and first and second quarter reports for FY 2022 were also not posted timely as required. No issues were noted with the accuracy of the disclosure, but the timing was past the required due date. Questioned costs: None Context: The Student Aid grant awards were not reported on the University?s website on a timely basis for the first and second quarters of FY22. Cause: The University established reporting processes according to the compliance supplement. However, in the process of assigning responsibility for each reporting requirement, this requirement of updating the HEERF award disclosures quarterly was missed. Effect: The HEERF Student Aid award information was not reported publicly on the University?s website. As a result, students and other interested parties did not have readily presented access to this data. Repeat finding: Yes ? 2021-001. The finding is limited to the HEERF Student Aid first and second quarter reporting of FY22. Recommendations: We recommend that the University have controls in place to ensure that all required reporting is performed timely. Views of responsible officials: HEERF was issued to institutions of higher education in the spring of 2020 to support students and campus operations in the midst of the COVID-19 pandemic. Quarterly reporting requirements were later established by the Department of Education. Student Aid grant award reporting was overlooked by the responsible official due to confusion of duty with the emergency relief program. When the prior-year finding was identified, a system of controls was established to ensure future compliance and timely reporting. Specifically, the responsible reporting officials for the institutional and student portions of HEERF funding combined report information into a single web posting request prior to the deadline each quarter. This single request provided another check for the posting official to confirm the quarterly report was comprehensive.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Criteria: Reporting ? Per 2 CFR Part 200.328 and 2CFR Part 200.329, institutions must publicly display on their website the total number of students who have received an Emergency Financial Aid Grant. Institutions are required to submit quarterly budget and expenditure reports detailing institutional expenditures of HEERF funds. Condition: The institution?s count of number of students who have received an Emergency Financial Aid Grant disclosed on the website is not accurate. A quarterly report for institutional portion expenditures was not submitted accurately. Questioned Costs: None. Context: Students eligible to receive an Emergency Financial Aid Grant were reported incorrectly. We received the listing of students used for the reporting disclosures and performed recounts. For the September 30, 2021 disbursement, the College reported 1,291 students received emergency funding instead of the actual number, 1,517, a difference of 226 students. Additionally, for the December 31, 2021 disbursement, the College reported 1,291 students received emergency funding instead of the actual number, 1,514, a difference of 223 students. Finally, the 4th quarter institutional share report inaccurately stated all disbursements were for lost revenues instead of $122,346 being allocated for COVID related expenses. Effect: The disclosures on the website are not accurate. Cause: Internal controls were not adequately designed and implemented to ensure compliance with the program?s reporting requirements. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend implementing controls to ensure the College complies with the programs reporting compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Administration concurs with the findings. The College has corrected the website disclosure of number of students receiving Aid Grants under the program. The College will review and confirm accuracy of any future report submissions. Anticipated Completion Date: May 31, 2023
Criteria: Reporting ? Per 2 CFR Part 200.328 and 2CFR Part 200.329, institutions must publicly display on their website the total number of students who have received an Emergency Financial Aid Grant. Institutions are required to submit quarterly budget and expenditure reports detailing institutional expenditures of HEERF funds. Condition: The institution?s count of number of students who have received an Emergency Financial Aid Grant disclosed on the website is not accurate. A quarterly report for institutional portion expenditures was not submitted accurately. Questioned Costs: None. Context: Students eligible to receive an Emergency Financial Aid Grant were reported incorrectly. We received the listing of students used for the reporting disclosures and performed recounts. For the September 30, 2021 disbursement, the College reported 1,291 students received emergency funding instead of the actual number, 1,517, a difference of 226 students. Additionally, for the December 31, 2021 disbursement, the College reported 1,291 students received emergency funding instead of the actual number, 1,514, a difference of 223 students. Finally, the 4th quarter institutional share report inaccurately stated all disbursements were for lost revenues instead of $122,346 being allocated for COVID related expenses. Effect: The disclosures on the website are not accurate. Cause: Internal controls were not adequately designed and implemented to ensure compliance with the program?s reporting requirements. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend implementing controls to ensure the College complies with the programs reporting compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Administration concurs with the findings. The College has corrected the website disclosure of number of students receiving Aid Grants under the program. The College will review and confirm accuracy of any future report submissions. Anticipated Completion Date: May 31, 2023
Finding 2022-001 ? Significant Deficiency: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds - Reporting Federal Program: COVID-19 Education Stabilization Fund Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number: 84.425E, 84.425F Federal Award Number: P425E200445 Federal Award Year: June 30, 2022 Criteria: Section 18004 of the Coronavirus Aid, Relief and Economic Security (CARES) ACT and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations (CRRSAA) Act directs institutions receiving funds to promptly and timely provide detailed accounting of the use and expenditures for HEERF (Higher Education Emergency Relief Funds) I, HEERF II, and HEERF III funds. Each institution is required to share in an easily accessible public location quarterly reports (September 30, December 31, March 31, June 30). The reporting is required for both the Student Portion and the Institutional Portion. While the American Rescue Plan (ARP) does not explicitly identify procedures by which institutions submit a report to the Secretary, the Department exercises this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Condition/Context: The College did not post the required quarterly reports for the Student Portion. Additionally, during the audit, it was noted that the College was unable to provide a copy of the annual report and supporting documentation for the year ended December 31, 2021. Cause: Staff turnover at the College was the primary factor leading to the issues noted above. Effect: The College did not provide the public and the Department with all required data related to HEERF and the Student Portion reports were not posted in a timely manner. Questioned Costs: Not applicable. Recommendation: The College should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management's Response: MCAD has experienced 100% turnover in the positions responsible for submitting the HEERF reporting. The internal data supporting these reports is accessible for future reporting to be done in a timely manner.
Finding 2022-001 ? Significant Deficiency: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds - Reporting Federal Program: COVID-19 Education Stabilization Fund Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number: 84.425E, 84.425F Federal Award Number: P425E200445 Federal Award Year: June 30, 2022 Criteria: Section 18004 of the Coronavirus Aid, Relief and Economic Security (CARES) ACT and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations (CRRSAA) Act directs institutions receiving funds to promptly and timely provide detailed accounting of the use and expenditures for HEERF (Higher Education Emergency Relief Funds) I, HEERF II, and HEERF III funds. Each institution is required to share in an easily accessible public location quarterly reports (September 30, December 31, March 31, June 30). The reporting is required for both the Student Portion and the Institutional Portion. While the American Rescue Plan (ARP) does not explicitly identify procedures by which institutions submit a report to the Secretary, the Department exercises this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Condition/Context: The College did not post the required quarterly reports for the Student Portion. Additionally, during the audit, it was noted that the College was unable to provide a copy of the annual report and supporting documentation for the year ended December 31, 2021. Cause: Staff turnover at the College was the primary factor leading to the issues noted above. Effect: The College did not provide the public and the Department with all required data related to HEERF and the Student Portion reports were not posted in a timely manner. Questioned Costs: Not applicable. Recommendation: The College should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management's Response: MCAD has experienced 100% turnover in the positions responsible for submitting the HEERF reporting. The internal data supporting these reports is accessible for future reporting to be done in a timely manner.
Finding 2022-001 Federal program: Education Stabilization Fund -Higher Education Emergency Relief Fund (HEERF): COVID-19 CARES Act- Student Aid Portion AL #: 84.425E Award Year: 2021/2022 Type of finding: Deficiency and Noncompliance Compliance requirement: Reporting - Special Reporting Criteria: Under 2 CFR 200.328 and 200.329, Universities must publicly post certain information relating to Student Aid awards on their website no later than 30 days after award, and update that information within 10 days after the end of every calendar quarter by posting a new report. Condition: Due to the timing of the prior year finding being identified, the award notification report, and first and second quarter reports for FY 2022 were also not posted timely as required. No issues were noted with the accuracy of the disclosure, but the timing was past the required due date. Questioned costs: None Context: The Student Aid grant awards were not reported on the University?s website on a timely basis for the first and second quarters of FY22. Cause: The University established reporting processes according to the compliance supplement. However, in the process of assigning responsibility for each reporting requirement, this requirement of updating the HEERF award disclosures quarterly was missed. Effect: The HEERF Student Aid award information was not reported publicly on the University?s website. As a result, students and other interested parties did not have readily presented access to this data. Repeat finding: Yes ? 2021-001. The finding is limited to the HEERF Student Aid first and second quarter reporting of FY22. Recommendations: We recommend that the University have controls in place to ensure that all required reporting is performed timely. Views of responsible officials: HEERF was issued to institutions of higher education in the spring of 2020 to support students and campus operations in the midst of the COVID-19 pandemic. Quarterly reporting requirements were later established by the Department of Education. Student Aid grant award reporting was overlooked by the responsible official due to confusion of duty with the emergency relief program. When the prior-year finding was identified, a system of controls was established to ensure future compliance and timely reporting. Specifically, the responsible reporting officials for the institutional and student portions of HEERF funding combined report information into a single web posting request prior to the deadline each quarter. This single request provided another check for the posting official to confirm the quarterly report was comprehensive.
Federal Agency: United States Department of Health and Human Services Federal Program: Head Start Federal Assistance Listing Number 93.600 Federal Award Year: 2021 to 2022 Criteria or Specific Requirement – Financial Reporting (2 CFR 200.328) and Monitoring and Reporting Program Performance (2 CFR 200.329) – Management is responsible for implementing controls to provide reasonable assurance that reports of federal awards submitted to the federal awarding agency or pass-through entity include all activity of the reporting period, are supported by underlying accounting or performance records, and are fairly presented in accordance with governing requirements. Management's control policies require segregation of duties between those preparing and those reviewing and filing required reports. Condition – Required reports were not separately reviewed for completeness and accuracy by an individual in management at the appropriate level other than the preparer as required by the Organization’s policy. Questioned Costs – None Context – Three of the twelve reports submitted during the year were selected for testing. Each of the three reports tested were not reviewed as required. The sampling methodology is not and is not intended to be statistically valid. Effect – Misstated reports may cause inaccurate information be submitted to the award agency and could impact future funding. Cause – The Organization’s internal controls were not adequate to ensure reports submitted were reviewed by a separate individual in management for completeness and accuracy prior to filing. Identification as a Repeat Finding – Not a repeat finding. Recommendation – We recommend management evaluate the need to implement additional procedures and policies to strengthen internal controls to ensure all required reports are reviewed for completeness and accuracy by a separate individual prior to filing. Views of Responsible Officials and Planned Corrective Actions – Management concurs with the finding. The Organization has implemented a process where a staff accountant will prepare the necessary reports, and the chief financial officer will review such reports. Alternatively, if the chief financial officer must prepare such reports, the review will be performed by the executive director.
Criteria: Section 18004 of the Coronavirus Aid, Relief and Economic Security (CARES) ACT and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations (CRRSAA) Act directs institutions receiving funds to promptly and timely provide detailed accounting of the use and expenditures for HEERF (Higher Education Emergency Relief Funds) I, HEERF II, and HEERF III funds. Each institution is required to share in an easily accessible public location quarterly reports (September 30, December 31, March 31, June 30). The reporting is required for both the Student Portion and the Institutional Portion. While the American Rescue Plan (ARP) does not explicitly identify procedures by which institutions submit a report to the Secretary, the Department exercises this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Condition/Context: The College did not post a report for the Student Portion of HEERF funds for the quarter ended June 30, 2021. This would have been the first quarter of HEERF III reporting and there were no funds disbursed to students during that quarter. The College posted to the website their quarterly report for September 30, 2021 with in the required timeframe. Upon review, it was noted that the report did not include the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CRRSAA and ARP (a)(1) and (a)(4) programs. Questioned Costs: Not applicable. Cause: The College missed the June 30th report as there were no expenditures from the Student Portion that quarter. The College also missed the requirement to report the estimated number of students eligible to receive Emergency Financial Aid Grants to Students. Effect: The College did not provide all of the information required for the HEERF Student Aid Portion. Recommendation: The College should correct the reporting to include the missing pieces. Management's Response: The College will update the September 30, 2021 quarterly report currently posted on the website to include the estimated number of students eligible for HEERF funds. The College will post an additional report for the quarter ending June 30, 2021, indicating the receipt of funds and that no funds were distributed during the quarter.
Finding No. 2022-007 Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.328 and applicable reporting requirements, the Program is required to submit an accurate SF-425, Federal Financial Report. Condition: For three (or 100%) SF-425 reports tested, the following variances were noted: 1. Grant Award H80CS31624 - 04/30/2022 Reporting Period End Date: 2. Grant Award H8DCS36429 - 03/31/2022 Reporting Period End Date: 3. Grant Award H8FCS41048 - 03/31/2022 Reporting Period End Date: Finding No. 2022-007, continued Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Cause: KCHC did not effectively monitor the accuracy and completeness of the SF 425 report based on underlying accounting records. Effect: KCHC is in noncompliance with the SF-425 federal reporting requirements. No questioned costs are presented as the variances are due to reporting errors. Identification as a Repeat Finding: Finding No. 2021-007 Recommendation: Responsible personnel should take steps to monitor reports and determine that expenditures and program income reported on the SF-425 report are supported by underlying accounting reports. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding. Refer to separate Corrective Action Plan.
Finding No. 2022-007 Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.328 and applicable reporting requirements, the Program is required to submit an accurate SF-425, Federal Financial Report. Condition: For three (or 100%) SF-425 reports tested, the following variances were noted: 1. Grant Award H80CS31624 - 04/30/2022 Reporting Period End Date: 2. Grant Award H8DCS36429 - 03/31/2022 Reporting Period End Date: 3. Grant Award H8FCS41048 - 03/31/2022 Reporting Period End Date: Finding No. 2022-007, continued Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Cause: KCHC did not effectively monitor the accuracy and completeness of the SF 425 report based on underlying accounting records. Effect: KCHC is in noncompliance with the SF-425 federal reporting requirements. No questioned costs are presented as the variances are due to reporting errors. Identification as a Repeat Finding: Finding No. 2021-007 Recommendation: Responsible personnel should take steps to monitor reports and determine that expenditures and program income reported on the SF-425 report are supported by underlying accounting reports. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding. Refer to separate Corrective Action Plan.
Finding No. 2022-007 Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.328 and applicable reporting requirements, the Program is required to submit an accurate SF-425, Federal Financial Report. Condition: For three (or 100%) SF-425 reports tested, the following variances were noted: 1. Grant Award H80CS31624 - 04/30/2022 Reporting Period End Date: 2. Grant Award H8DCS36429 - 03/31/2022 Reporting Period End Date: 3. Grant Award H8FCS41048 - 03/31/2022 Reporting Period End Date: Finding No. 2022-007, continued Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Cause: KCHC did not effectively monitor the accuracy and completeness of the SF 425 report based on underlying accounting records. Effect: KCHC is in noncompliance with the SF-425 federal reporting requirements. No questioned costs are presented as the variances are due to reporting errors. Identification as a Repeat Finding: Finding No. 2021-007 Recommendation: Responsible personnel should take steps to monitor reports and determine that expenditures and program income reported on the SF-425 report are supported by underlying accounting reports. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding. Refer to separate Corrective Action Plan.
Criteria: Section 18004 of the Coronavirus Aid, Relief and Economic Security (CARES) ACT and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations (CRRSAA) Act directs institutions receiving funds to promptly and timely provide detailed accounting of the use and expenditures for HEERF (Higher Education Emergency Relief Funds) I, HEERF II, and HEERF III funds. Each institution is required to share in an easily accessible public location quarterly reports (September 30, December 31, March 31, June 30). The reporting is required for both the Student Portion and the Institutional Portion. While the American Rescue Plan (ARP) does not explicitly identify procedures by which institutions submit a report to the Secretary, the Department exercises this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Condition/Context: The College did not post a report for the Student Portion of HEERF funds for the quarter ended June 30, 2021. This would have been the first quarter of HEERF III reporting and there were no funds disbursed to students during that quarter. The College posted to the website their quarterly report for September 30, 2021 with in the required timeframe. Upon review, it was noted that the report did not include the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CRRSAA and ARP (a)(1) and (a)(4) programs. Questioned Costs: Not applicable. Cause: The College missed the June 30th report as there were no expenditures from the Student Portion that quarter. The College also missed the requirement to report the estimated number of students eligible to receive Emergency Financial Aid Grants to Students. Effect: The College did not provide all of the information required for the HEERF Student Aid Portion. Recommendation: The College should correct the reporting to include the missing pieces. Management's Response: The College will update the September 30, 2021 quarterly report currently posted on the website to include the estimated number of students eligible for HEERF funds. The College will post an additional report for the quarter ending June 30, 2021, indicating the receipt of funds and that no funds were distributed during the quarter.
Finding No. 2022-007 Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.328 and applicable reporting requirements, the Program is required to submit an accurate SF-425, Federal Financial Report. Condition: For three (or 100%) SF-425 reports tested, the following variances were noted: 1. Grant Award H80CS31624 - 04/30/2022 Reporting Period End Date: 2. Grant Award H8DCS36429 - 03/31/2022 Reporting Period End Date: 3. Grant Award H8FCS41048 - 03/31/2022 Reporting Period End Date: Finding No. 2022-007, continued Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Cause: KCHC did not effectively monitor the accuracy and completeness of the SF 425 report based on underlying accounting records. Effect: KCHC is in noncompliance with the SF-425 federal reporting requirements. No questioned costs are presented as the variances are due to reporting errors. Identification as a Repeat Finding: Finding No. 2021-007 Recommendation: Responsible personnel should take steps to monitor reports and determine that expenditures and program income reported on the SF-425 report are supported by underlying accounting reports. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding. Refer to separate Corrective Action Plan.
Finding No. 2022-007 Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.328 and applicable reporting requirements, the Program is required to submit an accurate SF-425, Federal Financial Report. Condition: For three (or 100%) SF-425 reports tested, the following variances were noted: 1. Grant Award H80CS31624 - 04/30/2022 Reporting Period End Date: 2. Grant Award H8DCS36429 - 03/31/2022 Reporting Period End Date: 3. Grant Award H8FCS41048 - 03/31/2022 Reporting Period End Date: Finding No. 2022-007, continued Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Cause: KCHC did not effectively monitor the accuracy and completeness of the SF 425 report based on underlying accounting records. Effect: KCHC is in noncompliance with the SF-425 federal reporting requirements. No questioned costs are presented as the variances are due to reporting errors. Identification as a Repeat Finding: Finding No. 2021-007 Recommendation: Responsible personnel should take steps to monitor reports and determine that expenditures and program income reported on the SF-425 report are supported by underlying accounting reports. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding. Refer to separate Corrective Action Plan.
Finding No. 2022-007 Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.328 and applicable reporting requirements, the Program is required to submit an accurate SF-425, Federal Financial Report. Condition: For three (or 100%) SF-425 reports tested, the following variances were noted: 1. Grant Award H80CS31624 - 04/30/2022 Reporting Period End Date: 2. Grant Award H8DCS36429 - 03/31/2022 Reporting Period End Date: 3. Grant Award H8FCS41048 - 03/31/2022 Reporting Period End Date: Finding No. 2022-007, continued Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Cause: KCHC did not effectively monitor the accuracy and completeness of the SF 425 report based on underlying accounting records. Effect: KCHC is in noncompliance with the SF-425 federal reporting requirements. No questioned costs are presented as the variances are due to reporting errors. Identification as a Repeat Finding: Finding No. 2021-007 Recommendation: Responsible personnel should take steps to monitor reports and determine that expenditures and program income reported on the SF-425 report are supported by underlying accounting reports. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding. Refer to separate Corrective Action Plan.
Finding 2021-006 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Reporting Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.328 - Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. 2 CFR 200.329(c)(1) -Requirements state that the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Condition: For three of the four reports selected for testing, CFSC did not submit the reports to the National Fish and Wildlife Foundation by the required date. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all four reports filed during year. The condition noted above was identified during our procedures over the CFSC’s reporting provisions. Repeat Finding from Prior Year: No Effect: CFSC did not submit required reports in a timely manner, increasing the risk of noncompliance. Cause: CFSC’s procedures did not consistently ensure that the required reports were submitted on a timely basis. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all required reports are submitted on a timely basis to the appropriate Federal Agency or Pass-Through Entity. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.
Finding 2021-007 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Reporting Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.302(b)(2) - Requirements state that there must be 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. Condition: Expenditures for one financial report that was selected for testing did not agree with the expenditures that were reported on the SEFA and recorded in the General Ledger (difference of $11,791), based on the dates requested in the report. CFSC did not include known operational expenses for the period that were program costs at the time the report was due, which resulted in underreporting expenditures by $11,791. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all four reports filed during year. The condition noted above was identified during our procedures over CFSC’s reporting provisions. Repeat Finding from Prior Year: No Effect: CFSC did not include all known expenditures at the time the report was submitted to the National Fish and Wildlife Foundation, increasing the risk of noncompliance. Cause: CFSC’s procedures did not consistently ensure that all known expenditures at the time the report was submitted were included. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all known expenditures are included at the time reports are required to be submitted. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.
Finding 2021-006 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Reporting Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.328 - Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. 2 CFR 200.329(c)(1) -Requirements state that the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Condition: For three of the four reports selected for testing, CFSC did not submit the reports to the National Fish and Wildlife Foundation by the required date. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all four reports filed during year. The condition noted above was identified during our procedures over the CFSC’s reporting provisions. Repeat Finding from Prior Year: No Effect: CFSC did not submit required reports in a timely manner, increasing the risk of noncompliance. Cause: CFSC’s procedures did not consistently ensure that the required reports were submitted on a timely basis. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all required reports are submitted on a timely basis to the appropriate Federal Agency or Pass-Through Entity. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.
Finding 2021-007 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Reporting Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.302(b)(2) - Requirements state that there must be 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. Condition: Expenditures for one financial report that was selected for testing did not agree with the expenditures that were reported on the SEFA and recorded in the General Ledger (difference of $11,791), based on the dates requested in the report. CFSC did not include known operational expenses for the period that were program costs at the time the report was due, which resulted in underreporting expenditures by $11,791. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all four reports filed during year. The condition noted above was identified during our procedures over CFSC’s reporting provisions. Repeat Finding from Prior Year: No Effect: CFSC did not include all known expenditures at the time the report was submitted to the National Fish and Wildlife Foundation, increasing the risk of noncompliance. Cause: CFSC’s procedures did not consistently ensure that all known expenditures at the time the report was submitted were included. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all known expenditures are included at the time reports are required to be submitted. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.
Lack of Documentation Related to Reporting (prior two years 2020-104 and 2019-106) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H80CS06452-15 (2020), H80CS06452-16 (2021) and COVID-19 ARP H8FCS40324 -01(2021) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer, as of March 2022, as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to included only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization
Lack of Documentation Related to Reporting (prior two years 2020-104 and 2019-106) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H80CS06452-15 (2020), H80CS06452-16 (2021) and COVID-19 ARP H8FCS40324 -01(2021) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer, as of March 2022, as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to included only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization
Lack of Documentation Related to Reporting (prior two years 2020-104 and 2019-106) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H80CS06452-15 (2020), H80CS06452-16 (2021) and COVID-19 ARP H8FCS40324 -01(2021) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer, as of March 2022, as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to included only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization
Lack of Documentation Related to Reporting (prior two years 2020-104 and 2019-106) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H80CS06452-15 (2020), H80CS06452-16 (2021) and COVID-19 ARP H8FCS40324 -01(2021) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer, as of March 2022, as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to included only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization
Lack of Controls Related to Filing Reports (initially reported 2021) Assistance Listing Number: 93.498 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: COVID-19 Provider Relief Fund Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: COVID-19 Provider Relief Fund (2020) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation to support the review of the report 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 did not have a process in place for review of the data being reported on the HRSA website for the funds being expensed under the Provider Relief Fund program. Effect: The Organization could submit incorrect information. Recommendation: The documentation should be kept that clearly documents 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.
Lack of Documentation Related to Reporting (prior two years 2020-104 and 2019-106) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H80CS06452-15 (2020), H80CS06452-16 (2021) and COVID-19 ARP H8FCS40324 -01(2021) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer, as of March 2022, as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to included only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization
Lack of Documentation Related to Reporting (prior two years 2020-104 and 2019-106) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H80CS06452-15 (2020), H80CS06452-16 (2021) and COVID-19 ARP H8FCS40324 -01(2021) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer, as of March 2022, as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to included only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization
Lack of Documentation Related to Reporting (prior two years 2020-104 and 2019-106) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H80CS06452-15 (2020), H80CS06452-16 (2021) and COVID-19 ARP H8FCS40324 -01(2021) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer, as of March 2022, as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to included only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization
Lack of Documentation Related to Reporting (prior two years 2020-104 and 2019-106) (initially reported 2018) Assistance Listing Number: 93.224 and 93.527 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: H80CS06452-15 (2020), H80CS06452-16 (2021) and COVID-19 ARP H8FCS40324 -01(2021) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation in support of reporting requirements. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also under compliance requirements for reporting 2 CFR 200.328 states that information must be collected with the frequency required by the terms and conditions of the federal award for effective monitoring of the federal awards. Cause: Supporting records used to populate the Uniform Data System (UDS) report were not retained by the Organization. Effect: The Organization could submit incorrect information. Recommendation: Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Views of Responsible Officials and Planned Corrective Action: The Organization has hired a new Chief Financial Officer, as of March 2022, as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to included only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization
Lack of Controls Related to Filing Reports (initially reported 2021) Assistance Listing Number: 93.498 Name of Federal Agency: Department of Health and Human Services, HRSA Program Title: COVID-19 Provider Relief Fund Compliance Requirement: Reporting Pass-through Entity: N/A Federal Grant/Contract Number and Grant Year: COVID-19 Provider Relief Fund (2020) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Organization did not maintain proper documentation to support the review of the report 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 did not have a process in place for review of the data being reported on the HRSA website for the funds being expensed under the Provider Relief Fund program. Effect: The Organization could submit incorrect information. Recommendation: The documentation should be kept that clearly documents 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 2021-001 Federal Program Title – Airport Improvement Program and COVID-19 Airport Improvement Program Assistance Listing No. – 20.106 Federal Agency – U.S. Department of Transportation – Direct Program Federal Award Number – 30601270472020 Grant Award Periods – May 7, 2020 to May 6, 2024 Compliance Requirement – Reporting Criteria: As set forth in 2 CFR 200.328, the Federal Financial Report, SF 425, 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. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Conditions Found: The City did not have an effective system of internal control in place to ensure the reports that are required to be submitted to the U.S. Department of Transportation were accurate. We selected a sample of nine reports and determined that one report omitted $18.4 million in payroll and payroll-related costs of which $3.6 million are costs incurred during the fiscal year ended September 30, 2021. Questioned Costs: There are no questioned costs. Context: The City is required to submit annual federal financial reports related to the Airport Improvement Program that include all disbursements for direct charges for property and services; the amount of indirect expense incurred; and the net increase or decrease in the amounts owed by the recipient for (1) goods and other property received; (2) services performed by employees, contractors, subrecipients, and other payees; and (3) programs for which no current services or performance are required. Cause and Effect: City management indicated that interpretation of the reporting requirements was that payments made to employees for services provided were required to be omitted from the SF 425 report. As a result, the reports submitted omitted $18.4 million in payroll and payroll-related costs. Repeat Finding: A similar finding was not reported in the prior-year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the City strengthen processes and internal controls to ensure the City has an effective internal control in place to ensure that reports are complete and accurate prior to submitting to the U.S. Department of Transportation as required. View of Responsible Official: The subject Airport Improvement Program (AIP) grant for COVID-19 related funding was used solely for internal City payroll-related expenditures and debt service payments, which is different from other previous AIP grants received by the Airport Department. The misinterpretation of reporting requirements for the new grant led to an error on the Federal Financial Report SF 425. The Airport Department will be providing more training to staff that are involved with the preparation, review and approval of the reports to reduce the risk of misinterpreting reporting requirements. The Airport Department will also strengthen internal controls by requiring at least two levels of review for Federal Financial Report SF 425, prior to submission. These improvements to the process will ensure that reports are complete and accurate.
Finding 2021-001 Federal Program Title – Airport Improvement Program and COVID-19 Airport Improvement Program Assistance Listing No. – 20.106 Federal Agency – U.S. Department of Transportation – Direct Program Federal Award Number – 30601270472020 Grant Award Periods – May 7, 2020 to May 6, 2024 Compliance Requirement – Reporting Criteria: As set forth in 2 CFR 200.328, the Federal Financial Report, SF 425, 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. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Conditions Found: The City did not have an effective system of internal control in place to ensure the reports that are required to be submitted to the U.S. Department of Transportation were accurate. We selected a sample of nine reports and determined that one report omitted $18.4 million in payroll and payroll-related costs of which $3.6 million are costs incurred during the fiscal year ended September 30, 2021. Questioned Costs: There are no questioned costs. Context: The City is required to submit annual federal financial reports related to the Airport Improvement Program that include all disbursements for direct charges for property and services; the amount of indirect expense incurred; and the net increase or decrease in the amounts owed by the recipient for (1) goods and other property received; (2) services performed by employees, contractors, subrecipients, and other payees; and (3) programs for which no current services or performance are required. Cause and Effect: City management indicated that interpretation of the reporting requirements was that payments made to employees for services provided were required to be omitted from the SF 425 report. As a result, the reports submitted omitted $18.4 million in payroll and payroll-related costs. Repeat Finding: A similar finding was not reported in the prior-year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the City strengthen processes and internal controls to ensure the City has an effective internal control in place to ensure that reports are complete and accurate prior to submitting to the U.S. Department of Transportation as required. View of Responsible Official: The subject Airport Improvement Program (AIP) grant for COVID-19 related funding was used solely for internal City payroll-related expenditures and debt service payments, which is different from other previous AIP grants received by the Airport Department. The misinterpretation of reporting requirements for the new grant led to an error on the Federal Financial Report SF 425. The Airport Department will be providing more training to staff that are involved with the preparation, review and approval of the reports to reduce the risk of misinterpreting reporting requirements. The Airport Department will also strengthen internal controls by requiring at least two levels of review for Federal Financial Report SF 425, prior to submission. These improvements to the process will ensure that reports are complete and accurate.
REPORTING, I DID NOT NOTE ANY OF THE REQUIRED QUARTERLY REPORTING FOR THE CARES ACT GRANT. I ALSO DID NOT NOTE ANY INTERIM OR ANNUAL REPORTS FILED FOR THE ARP GRANT. PER 2 CFR, SECTION 200.328 AND 200.329, THE NVT MUST COMPLY WITH ANY FINANCIAL AND PROGRAMMATIC 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 ANY OF THE 4 QUARTERLY FINANCIAL OR NARRATIVE REPORTS FOR THE CARES ACT GRANT. I WAS ALSO NOT ABLE TO REVIEW THE ANNUAL REQUIRED REPORT FOR THE ARP GRANT. THE NVT IS DELINQUENT IN ITS REPORTING FOR THESE TWO GRANTS. MANAGEMENT NEEDS TO ENSURE THAT ALL GRANT REPORTS ARE DONE AND SUBMITTED TIMELY AND RETAINED WITHIN THE GRANT FILES OF THE NVT. THIS FINDING WAS NOTED AS FINDING 2020-002.
OTHER, THE NVT DID NOT SUBMIT THE REPORTING PACKAGE TIMELY IN ACCORDANCE WITH THE UNIFORM GUIDANCE REQUIREMENT OF SUBMITTING THE AUDIT WITHIN THE EARLIER OF 30 DAYS AFTER RECEIPT OF THE AUDIT REPORT, OR NINE MONTHS AFTER THE END OF THE AUDIT PERIOD. PER 2 CFR, SECTION 200.328 AND 200.329, THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATTIC REPORTING REQUIREMENTS. PER SECTION 200.501, THE NVT MUST HAEV AN AUDIT PERFORMED AND SUBMITTED WITHIN 9 MONTHS OF YEAR END. NO QUESTIONED COSTS. MANAGEMENT DID NOT ENSURE THAT THE AUDITS WERE PERFORMED TIMELY. LATE REPORTING COULD JEOPARDIZE GRANT FUNDING. I RECOMMEND THAT THE COUNCIL ENSURE TIMELY AUDITS FOR FUTURE AUDITS. THIS FINDING WAS NOTED AS FINDING 2020-003
PUBLIC BUILDINGS AUTHORITY (A Component Unit of the Commonwealth of Puerto Rico) SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR THE YEAR ENDED JUNE 30, 2021 Finding Number: 2021-003 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, 2021 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 noted differences between quarterly reports amounts submitted to grantee agency and expense amounts accrued during the year. PW Number on large projects//Quarter//Quater ended//Deadline//Reported costs as per QPR//Costs as per SEFA 2021 PW-4339-2602 // 3 // 6-30-2021 // 7-31-2021 // - // 502,879 PW-4339-4206 // 3 // 6/30/2021 // 7/31/2021 // - // 1,290,050 PW-4339-5823 // 3 // 6/30/2021 // 7/31/2021 // - // 223,731 PW-4339-7235 // 3 // 6/30/2021 // 7/31/2021 // - // 259,085 PW-4339-8298 // 3 // 6/30/2021 // 7/31/2021 // - // 462,364 PW-4339-8314 // 3 // 6/30/2021 // 7/31/2021 // - // 251,917 PW-4339-8342 // 3 // 6/30/2021 // 7/31/2021 // - // 465,357 Cause: Missing of supporting documentation and underlying data. Effect: Wrong reported amounts could significantly affect program outcomes. Recommendation: To keep, document, file and trace supporting data 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 funds firm was hired that is working on internal controls to improve the method of accounting of federal funds that meet accounting and FEMA requirements. Responsible Officer: Mr. José R. González De la Vega Estimated Completion Date: To work it on or before December 2023.
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.