Program Information: Assistance Listing #: 93.445 U.S. Department of Health and Human Services I.H.S. Water Tank Replacement Award Numbers: PH12-U35, RN21-15 Award Periods: 7/29/2021-7/29/2025 Criteria: Federal grant agreements and related regulations require recipients to submit “Progress/Performance Reports,” due quarterly. These reports must compare actual accomplishments to established goals and objectives, explain any variances, and summarize activities and milestones, in accordance with the terms set by the awarding agency and detailed in the grant agreement (CFR § 200.329) Condition/Context: The Tribe was unable to provide copies of the required quarterly progress/performance reports, and as a result, we could not verify whether the reports were submitted to the awarding agency as required. [ X ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: The Tribe did not retain copies of the required performance reports, and procedures for maintaining federal reporting documentation were not consistently followed. Turnover in management likely contributed to the lack of record retention. Effect: Because the Tribe did not maintain documentation, we were unable to determine whether required performance reports were submitted. Failure to submit required reports could lead to delayed payments from the grantor or denial of eligibility for future grants from the awarding agency. Questioned Costs: None noted. This is a reporting and documentation finding; no costs are questioned. Repeat Finding: No. Recommendation: We recommend the Tribe implement a formal process to track required federal reporting deadlines and ensure that copies of all submitted reports are maintained in the grant files. This may include establishing a reporting calendar, designating a responsible staff member to complete and retain the reports, and implementing a supervisory review to ensure compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
2 CFR 1000.10 provides that, except for the deviations set forth elsewhere in this Part, the Department of Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards set forth at 2 CFR Part 200. 2 CFR 200.329(c)(1) states that non-Federal entities must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. 31 CFR 35.4(c) requires recipients, in part, during the period of performance, to provide the Secretary of the U.S. Department of Treasury periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. The U.S. Department of Treasury provided supplementary information in its interim final rule on reporting requirements for State and Local Fiscal Recovery Funds for 31 CFR Part 35 and provided further guidance in its Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance. The Compliance and Reporting Guidance, part 2 states that counties with a population below 250,000 residents must submit a Project and Expenditure Report by April 30, 2022 and then annually thereafter through the end of the award period on December 31, 2026. The City was required to submit a Project and Expenditure Report by April 30, 2023, to the U.S. Department of the Treasury through the Treasury’s Portal. However, the lack of adequate control procedures in place for reporting resulted in the City failing to submit the required report. Also, the lack of adequate control procedures in place for reporting resulted in the City incorrectly reporting obligated and expense amounts in the report due April 30, 2024, for the activity of April 1, 2023 - March 31, 2024, the City over-reported current period expenditures and current period obligations in the amount of $230,388. Failure to have the proper controls in place to ensure the accurate submission of the Project and Expenditure Reports could result in Treasury taking action against the City for failure to comply with programmatic requirements. The City should implement and have controls in place to ensure the annual Project and Expenditure Reports are accurate.
2 CFR 1000.10 gives regulatory effect to the Department of Treasury for 2 CFR part 200.302. CFR 200.302(a) states, in part, the non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.302(b)(2) further states, in part, the financial management system of each non-Federal entity must provide for accurate, current, and complete disclosures of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. Additionally, the Ohio Department of Development (ODOD) Water and Wastewater Infrastructure Program Grant Agreement provides in Exhibit II that "Program reports must be submitted on a quarterly basis. Program reports must be submitted by close of business, on the second Friday at the end of each quarter.” Due to deficiencies in the City’s internal controls over reporting, the City did not submit quarterly program reports for any quarter in 2024. Failure to submit required quarterly program reports could result in the City not receiving the reimbursements that it is entitled to. The City should implement internal controls to ensure that reports are submitted by the required deadlines per reporting requirements.
Finding Number: 2023-003 Assistance Listing Number and Title: Coronavirus State And Local Fiscal Recovery Funds AL # 21.027 Federal Award Identification Number: 2022ARCCB1134/ 2022-AR-LEP-937 Federal Agency: U.S. Department of Treasury Compliance Requirement: Reporting Pass-Through Entity: Ohio Department of Public Safety Repeat Finding from Prior Audit? No Noncompliance and Material Weakness 2 CFR § 1000.10 gives regulatory effect to Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200 for the Department of Treasury. 2 CFR 200.329 provides the recipient and subrecipient are responsible for the oversight of the Federal award. The recipient and subrecipient must monitor their activities under Federal awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient and subrecipient must cover each program, function, or activity. The Office of Criminal Justice Service Standard Subgrant Conditions Handbook provides all OCJS projects are required to submit Quarterly Subgrant Reports. This report must show actual expenditures, describe progress towards achieving objectives, and include supporting documentation (such as purchase orders, vouchers, invoices, payroll allocation reports, payroll summaries, timesheets, etc.) for expenditures. The reports shall be submitted no later than the last day of the month following the calendar quarter end. A report must be submitted every quarter, even when there has been zero expenditure or when a payment is not being requested. • The City submitted the quarterly report for the quarter ending March 31, 2023 for the COVID-19: Coronavirus State And Local Fiscal Recovery Funds AL# 21.027 Marietta Municipal Court Diversion/Backlog Grant 2022ARCCB1134 after the required deadline. • The City submitted the quarterly report for the quarter ending March 31, 2023 for the COVID-19: Coronavirus State And Local Fiscal Recovery Funds AL# 21.027 Employee Retention Grant 2022-AR-LEP-937 after the required deadline. Further, the City did not submit a report for the quarter ended September 30, 2023. The failure to timely submit the required reports was due to insufficient controls and could result in action taken by the pass-through entity. The City should establish procedures to help ensure all required reports are submitted timely.
"reports or supporting documentation, nor could they demonstrate that reporting requirements were consistently tracked, reviewed, or completed in a timely manner. As a result, we were unable to verify whether required reports were prepared accurately, submitted timely, or submitted at all during the audit period. Criteria Under 2 CFR 200.328 (Financial Reporting) and 2 CFR 200.329 (Monitoring and Reporting Program Performance), non-federal entities are required to submit accurate, complete, and timely financial and performance reports as specified in the terms and conditions of the federal award. Additionally, 2 CFR 200.303 (Internal Controls) requires that organizations maintain effective internal controls to ensure compliance with federal statutes, regulations, and award requirements, including reporting obligations. Cause These deficiencies appear to result from the absence of a formal reporting process, lack of oversight and monitoring of reporting requirements, and insufficient internal controls to ensure that required reports are prepared, reviewed, and submitted in accordance with federal guidelines. Effect The failure to prepare and submit required reports results in: ▪ Noncompliance with federal award requirements ▪ Increased risk that financial and program information reported to the granting agency is incomplete or inaccurate ▪ Potential for funding delays, suspension, or termination ▪ Increased exposure to regulatory scrutiny and audit findings ▪ Impaired ability of the awarding agency to monitor program performance and financial activity Questioned Costs Likely Questioned Costs: Undeterminable CARESTL HEALTH SCHEDULE OF FINDINGS AND QUESTIONED COSTS YEAR ENDED DECEMBER 31, 2022 46 SECTION III – FEDERAL AWARD FINDINGS AND QUESTION COSTS (Continued) The failure to prepare and submit required financial and performance reports constitutes a material weakness in internal control over compliance and results in noncompliance with federal reporting requirements. Recommendation We recommend that management: ▪ Establish a formal reporting calendar outlining all required financial and performance reports, including due dates ▪ Implement procedures to ensure reports are prepared accurately, reviewed, and submitted timely ▪ Maintain documentation of submitted reports, including confirmation of submission and supporting schedules ▪ Assign clear responsibility for reporting compliance and implement supervisory review controls ▪ Provide training to relevant personnel on federal reporting requirements Strengthening reporting processes will improve compliance, enhance transparency, and ensure that the organization meets its obligations under federal awards. Management Response Management respectfully disagrees with the conclusion that CareSTL Health failed to submit required financial and performance reports. All required federal grant reports, financial reports, and performance submissions were uploaded in full to the auditor portal on April 13, 2026. The documentation was downloaded directly from the Electronic Handbook in which the documents were originally submitted to HRSA. The circumstances described in the finding do not reflect a lack of internal controls or noncompliance with 2 CFR 200.328, 200.329, or 200.303. Rather, the perception of non submission appears to have resulted from timing constraints during the audit fieldwork period and the volume of overlapping federal requests occurring simultaneously. As noted in our financial management response to HRSA, the organization was navigating significant operational strain, including: ▪ An unexpected, unannounced full operational site visit that diverted key personnel ▪ Reimbursement only funding constraints that limited staffing capacity ▪ Multiple concurrent federal deadlines that compressed the audit preparation window Despite these challenges, CareSTL Health did submit all required reports, and documentation confirming submission was made available through the auditor portal. CARESTL HEALTH SCHEDULE OF FINDINGS AND QUESTIONED COSTS YEAR ENDED DECEMBER 31, 2022 47 SECTION III – FEDERAL AWARD FINDINGS AND QUESTION COSTS (Continued) Management agrees with the recommendations provided and views them as aligned with improvements already underway. To further strengthen reporting processes, the organization will: ▪ Establish a formal reporting calendar with all required federal due dates ▪ Implement procedures to ensure reports are prepared, reviewed, and submitted timely ▪ Maintain documentation of all submissions, including confirmations and supporting schedules ▪ Assign clear responsibility for reporting compliance and supervisory review ▪ Provide training to relevant personnel on federal reporting requirements These enhancements will reinforce our existing controls and ensure continued compliance, transparency, and timely reporting under all federal awards."
Health Center Program Cluster ALN Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No.2 H80CS00800, June 1, 2023 - May 31, 2024 Award No.5 H80CS00800, June 1, 2022 - May 31, 2023 Award No.3 H8FCS41036, April 1, 2021 - March 31, 2023 Criteria or Specific Requirement – Reporting – 2 CFR 200.328 and 2 CFR 200.329 Condition – The Organization is required to prepare and submit an annual Uniform Data System (UDS) report for each calendar year and an annual Federal Financial Report (FFR) for each grant year for the Health Center Cluster. These reports are to be prepared using accurate financial information. Cause – The Organization was unable to provide supporting documentation that agreed to the line items tested in the reports. The Organization’s practice management system was incorrectly set up to classify certain adjustments as sliding fee discounts and a manual correction was not made during the preparation of the UDS report. Effect or Potential Effect – Potential errors were made on the annual UDS and FFR reports. Questioned Cost – None Context – The annual UDS report and annual FFR were selected for testing out of total population of three reports. The sampling methodology used is not and is not intended to be statistically valid. Of the ten inputs tested, five exceptions were noted related to the annual UDS report. The FFR report tested was not accurately reported or could not be properly supported. Identification as a repeat finding, if applicable – Not a repeat finding. Recommendation – Management should follow established policies and procedures to ensure the required reports are prepared using accurate information and supporting documentation for federal grant reports are maintained. Views of responsible officials and planned corrective actions - Management agrees with the recommendation to ensure the required reports are prepared using accurate information and supporting documentation for federal grant reports are maintained. • All system generated reports will be maintained in the preparation of the UDS and FFR reports. • A report will be run out of the practice management system identifying qualified sliding fee discounts to be included in the UDS report. Anticipated date of completion: December 31, 2026 Contact person responsible – Margaret Boemmel, CFO
2023 – 004 Reporting Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP3738 11/30/2021 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit performance reports required by Federal award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the reported projects and expenditures accurately reflect what is reported in the expenditure detail and amounts obligated should reflect total procurement amounts awarded. Condition: While the correct expenditures were reported on the schedule of expenditures of federal awards, the expenditure reports filed during the year did not accurately report project details. Cumulative expenditures should report amounts expended through the end of the period and cumulative obligations should report total procurement amounts awarded. Questioned costs: None Context: The County incorrectly reported cumulative expenditures and cumulative obligations in 4 of 4 reports tested. Cause: Total cumulative expenditures were not reconciled to total amounts reported in the ledger. Reported project obligations were based on projects costs that been incurred and not contract sum awarded. Effect: Noncompliance with reporting requirements. Repeat Finding: This finding is a partial repeat of a finding in the prior year. The prior year finding number was 2022-004. Recommendation: We recommend the County strengthen its review procedures over reports. Total cumulative expenditures and total cumulative obligations reported should reconcile to the total amounts reported in the project accounting records used to support the SEFA. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP4201 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit performance reports required by Federal award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the reported projects and expenditures accurately reflect what is reported in the expenditure detail and amounts obligated should reflect total procurement amounts awarded. Condition: While the correct expenditures were reported on the schedule of expenditures of federal awards, the performance report filed during the year did not accurately report project details. Current period expenditures and obligations should have reported amounts expended and procurement amounts awarded during the reporting period and cumulative expenditure and obligations should have reported amounts expended and procurement amounts awarded from the start of the grant through the end of the reporting period. Questioned costs: None Context: 1 of 1 tested for reporting documentation. Cause: Total current period expenditures and obligations and total cumulated expenditures and obligations were not reconciled to the expenditure detail and procurement award detail. Prior period performance report overstated current period expenditures and obligations. These errors were corrected through current period performance report tested which causes current period expenditures and obligations to be understated. Effect: Cost could be disallowed as UGG not followed. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2022-005. Recommendation: We recommend the County perform a reconciliation of the project details reported to the expenditure detail and procurement amounts awarded detail used to support the SEFA, and these reconciliations be reviewed, to ensure accuracy and completeness of the reporting. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 004 Reporting Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP3738 11/30/2021 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit performance reports required by Federal award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the reported projects and expenditures accurately reflect what is reported in the expenditure detail and amounts obligated should reflect total procurement amounts awarded. Condition: While the correct expenditures were reported on the schedule of expenditures of federal awards, the expenditure reports filed during the year did not accurately report project details. Cumulative expenditures should report amounts expended through the end of the period and cumulative obligations should report total procurement amounts awarded. Questioned costs: None Context: The County incorrectly reported cumulative expenditures and cumulative obligations in 4 of 4 reports tested. Cause: Total cumulative expenditures were not reconciled to total amounts reported in the ledger. Reported project obligations were based on projects costs that been incurred and not contract sum awarded. Effect: Noncompliance with reporting requirements. Repeat Finding: This finding is a partial repeat of a finding in the prior year. The prior year finding number was 2022-004. Recommendation: We recommend the County strengthen its review procedures over reports. Total cumulative expenditures and total cumulative obligations reported should reconcile to the total amounts reported in the project accounting records used to support the SEFA. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP4201 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit performance reports required by Federal award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the reported projects and expenditures accurately reflect what is reported in the expenditure detail and amounts obligated should reflect total procurement amounts awarded. Condition: While the correct expenditures were reported on the schedule of expenditures of federal awards, the performance report filed during the year did not accurately report project details. Current period expenditures and obligations should have reported amounts expended and procurement amounts awarded during the reporting period and cumulative expenditure and obligations should have reported amounts expended and procurement amounts awarded from the start of the grant through the end of the reporting period. Questioned costs: None Context: 1 of 1 tested for reporting documentation. Cause: Total current period expenditures and obligations and total cumulated expenditures and obligations were not reconciled to the expenditure detail and procurement award detail. Prior period performance report overstated current period expenditures and obligations. These errors were corrected through current period performance report tested which causes current period expenditures and obligations to be understated. Effect: Cost could be disallowed as UGG not followed. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2022-005. Recommendation: We recommend the County perform a reconciliation of the project details reported to the expenditure detail and procurement amounts awarded detail used to support the SEFA, and these reconciliations be reviewed, to ensure accuracy and completeness of the reporting. Views of responsible officials: There is no disagreement with the audit finding.
FINDING 2023-002 Federal Program Information: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Transitional Living for Homeless Youth (ALN 93.550) Basic Center Grant (ALN 93.623) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting: 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 (2 CFR 200.329 (c)(1)). Condition: For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Cause: Lack of administrative oversight in regard to periodic reporting. Effect or Potential Effect: The Organization was not in compliance with the reporting requirements. Questioned Costs: None. Context: The U.S. Department of Health and Human Services requires semi-annual federal financial reports be submitted into the HHS Payment Management System (PMS) and semi-annual performance progress reports be submitted into the GrantSolutions system 30 days after the end of the semi-annual period. For 2 semi-annual financial reports selected and 2 semi-annual performance report selected, the reports were not submitted within the required timeframe. The pass-through entity, Mecklenburg County, requires subrecipients to submit monthly expenditure and performance reports via email 15 days after each month end. For 2 months selected, the reports were not submitted within the required timeframe. For 3 months selected, the Organization was unable to provide evidence of submission. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Organization enhance its procedures to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions: To prevent further late reports, internal calendar notifications will be added to the Executive Director and Program Director’s calendars. The Director of Finance & Business will monitor status of report submissions. The Chief of Staff of the program will maintain adequate documentation of report submissions.
FINDING 2023-002 Federal Program Information: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Transitional Living for Homeless Youth (ALN 93.550) Basic Center Grant (ALN 93.623) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting: 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 (2 CFR 200.329 (c)(1)). Condition: For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Cause: Lack of administrative oversight in regard to periodic reporting. Effect or Potential Effect: The Organization was not in compliance with the reporting requirements. Questioned Costs: None. Context: The U.S. Department of Health and Human Services requires semi-annual federal financial reports be submitted into the HHS Payment Management System (PMS) and semi-annual performance progress reports be submitted into the GrantSolutions system 30 days after the end of the semi-annual period. For 2 semi-annual financial reports selected and 2 semi-annual performance report selected, the reports were not submitted within the required timeframe. The pass-through entity, Mecklenburg County, requires subrecipients to submit monthly expenditure and performance reports via email 15 days after each month end. For 2 months selected, the reports were not submitted within the required timeframe. For 3 months selected, the Organization was unable to provide evidence of submission. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Organization enhance its procedures to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions: To prevent further late reports, internal calendar notifications will be added to the Executive Director and Program Director’s calendars. The Director of Finance & Business will monitor status of report submissions. The Chief of Staff of the program will maintain adequate documentation of report submissions.
FINDING 2023-002 Federal Program Information: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Transitional Living for Homeless Youth (ALN 93.550) Basic Center Grant (ALN 93.623) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting: 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 (2 CFR 200.329 (c)(1)). Condition: For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Cause: Lack of administrative oversight in regard to periodic reporting. Effect or Potential Effect: The Organization was not in compliance with the reporting requirements. Questioned Costs: None. Context: The U.S. Department of Health and Human Services requires semi-annual federal financial reports be submitted into the HHS Payment Management System (PMS) and semi-annual performance progress reports be submitted into the GrantSolutions system 30 days after the end of the semi-annual period. For 2 semi-annual financial reports selected and 2 semi-annual performance report selected, the reports were not submitted within the required timeframe. The pass-through entity, Mecklenburg County, requires subrecipients to submit monthly expenditure and performance reports via email 15 days after each month end. For 2 months selected, the reports were not submitted within the required timeframe. For 3 months selected, the Organization was unable to provide evidence of submission. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Organization enhance its procedures to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions: To prevent further late reports, internal calendar notifications will be added to the Executive Director and Program Director’s calendars. The Director of Finance & Business will monitor status of report submissions. The Chief of Staff of the program will maintain adequate documentation of report submissions.
FINDING 2023-002 Federal Program Information: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Transitional Living for Homeless Youth (ALN 93.550) Basic Center Grant (ALN 93.623) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting: 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 (2 CFR 200.329 (c)(1)). Condition: For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Cause: Lack of administrative oversight in regard to periodic reporting. Effect or Potential Effect: The Organization was not in compliance with the reporting requirements. Questioned Costs: None. Context: The U.S. Department of Health and Human Services requires semi-annual federal financial reports be submitted into the HHS Payment Management System (PMS) and semi-annual performance progress reports be submitted into the GrantSolutions system 30 days after the end of the semi-annual period. For 2 semi-annual financial reports selected and 2 semi-annual performance report selected, the reports were not submitted within the required timeframe. The pass-through entity, Mecklenburg County, requires subrecipients to submit monthly expenditure and performance reports via email 15 days after each month end. For 2 months selected, the reports were not submitted within the required timeframe. For 3 months selected, the Organization was unable to provide evidence of submission. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Organization enhance its procedures to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions: To prevent further late reports, internal calendar notifications will be added to the Executive Director and Program Director’s calendars. The Director of Finance & Business will monitor status of report submissions. The Chief of Staff of the program will maintain adequate documentation of report submissions.
Compliance with Reporting Requirements Federal Agency: U.S. Department of Education Information on Federal Program: Client Assistance Program, Assistance Listing 84.161 Criteria: 2 CFR section 200.329 requires the submission of Federal Financial Report SF-425, annually. Statement of Condition: Our testing over financial reporting included the timely submission of the annual report during DRNY’s fiscal year-end. The annual report for Contract H161A220065 due October 31, 2022, was not filed until November 15, 2022. We also viewed the report for the FY23 grant, noting it was due October 31, 2023 and submitted October 10, 2023. Statement of Cause: There were some discrepancies in due dates for the annual SF-425 report listed between the grant award notice and the filing website. The filing website had noted in the language that annual reports were due 90 days after the fiscal year-end, in which case, DRNY would have been in compliance. Statement of Effect: Annual reports noted above were not filed within the required reporting deadline. Questioned Costs: None Perspective Information: As part of testing the compliance with the reporting requirements of the program, the submission of the annual SF-425, due within the period under audit, is reviewed for timeliness of submission. Identification of Repeat Finding: No Recommendation: Disability Rights New York should develop a tracking system for when their various grant reports are due based on the grant award notices to ensure timely filing of their annual reports. View of Responsible Officials and Corrective Action Plan: Since the late submissions in November 2022, DRNY has ensured that the SF425s were submitted in accordance with the due dates per the Grant Award notices (GANs). Further DRNY has now calendared within Outlook all the grant reporting requirements required for awards for the next year and created an Excel tracking sheet of all the remaining reporting required for current grants. Both the Executive Director and the CFO have access to this Excel tracking and the calendar invites. As new GANs are received, the CFO will calendar in the tracking document all reporting requirements and within Outlook send out invites each calendar year and copy the Executive Director on those calendar invites. CFO will confirm to Executive Director as these reports are complete and document in the Excel tracker. Danielle Myers, CFO, is responsible for the resolution of this corrective action plan by 3/1/2024.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Treasury Department Federal Financial Assistance Listing 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement – Reporting Material Weakness in Internal Control over Compliance Criteria: Non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly, except in unusual circumstances, using a form or format authorized by OMB (2 CFR section 200.329). They also may be required to submit special reports as required by the terms and conditions of the federal award. For the Coronavirus State and Local Fiscal Recovery Funds, the City is required to submit the Project and Expenditure Report quarterly. Condition: We noted that while the City submitted the reports as required, the reports contained errors including incorrect amounts and reporting information on the incorrect line items. Cause: The City did not have processes in place to ensure that amounts and information being reported to the Treasury contained accurate and complete information, and that the information being reported was on the correct line. Effect: The City submitted inaccurate reports to Treasury. While the City ultimately corrected the reports with their final annual report submission, the timing of the corrected report was outside the Treasury allowed timeframe of 60 days after the report. Questioned Costs: None reported. Context/Sampling: Sampling was not used as 100% of the reports that were required to be submitted were tested. Repeat Finding from Prior Year(s): No Recommendation: The City should review their current practices and procedures for federal compliance reporting to ensure that the information being reported is complete and accurate. Views of Responsible Officials: The City concurs with the auditor’s findings.
U.S. Treasury Department Federal Financial Assistance Listing 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement – Reporting Material Weakness in Internal Control over Compliance Criteria: Non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly, except in unusual circumstances, using a form or format authorized by OMB (2 CFR section 200.329). They also may be required to submit special reports as required by the terms and conditions of the federal award. For the Coronavirus State and Local Fiscal Recovery Funds, the City is required to submit the Project and Expenditure Report quarterly. Condition: We noted that while the City submitted the reports as required, the reports contained errors including incorrect amounts and reporting information on the incorrect line items. Cause: The City did not have processes in place to ensure that amounts and information being reported to the Treasury contained accurate and complete information, and that the information being reported was on the correct line. Effect: The City submitted inaccurate reports to Treasury. While the City ultimately corrected the reports with their final annual report submission, the timing of the corrected report was outside the Treasury allowed timeframe of 60 days after the report. Questioned Costs: None reported. Context/Sampling: Sampling was not used as 100% of the reports that were required to be submitted were tested. Repeat Finding from Prior Year(s): No Recommendation: The City should review their current practices and procedures for federal compliance reporting to ensure that the information being reported is complete and accurate. Views of Responsible Officials: The City concurs with the auditor’s findings.
Finding 2023-007 – Reporting (Significant Deficiency and Noncompliance) Information on the federal program: U.S. Department of Health and Human Services, Assistance Listing #93.137 Community Programs to Improve Minority Health Grant Program. Criteria: 2 CFR section 200.328 establishes the requirements for timely and accurate financial reporting requirements and 2 CFR 200.329 establishes responsibility for reporting activities under the grant. Both financial and programmatic reporting requires the nonfederal entity to establish internal controls to ensure accuracy of reports. Condition: We tested on financial and one programmatic report filed for this grant during the year. For the programmatic report, data reported for accomplishments and clients served was not clearly supported. In addition, review and approval of the report was not clearly documented. Cause: Results reported in the programmatic report were supported by time sheets and client internal notes. This support was not summarized or categorized in a manner in which the reported data could be traced back to the support. Employees involved in the preparing and filing of these reports are copied on email submission but a review and approval prior to submission was not documented. Effect: The Council did not comply with reporting control requirements. Questioned Costs: None reported Recommendation: We recommend the Council strengthen procedures and documentation policies to ensure program accomplishments are adequately supported by records that are accumulated and summarized in accordance with the required criteria. Procedures should also be strengthened to include a clear review and approval process to be documented prior to report submission. Views of Responsible Officials: See Management’s View and Corrective Action Plan at the end of the report.
FINDING 2023-002 Federal Program Information: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Transitional Living for Homeless Youth (ALN 93.550) Basic Center Grant (ALN 93.623) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting: 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 (2 CFR 200.329 (c)(1)). Condition: For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Cause: Lack of administrative oversight in regard to periodic reporting. Effect or Potential Effect: The Organization was not in compliance with the reporting requirements. Questioned Costs: None. Context: The U.S. Department of Health and Human Services requires semi-annual federal financial reports be submitted into the HHS Payment Management System (PMS) and semi-annual performance progress reports be submitted into the GrantSolutions system 30 days after the end of the semi-annual period. For 2 semi-annual financial reports selected and 2 semi-annual performance report selected, the reports were not submitted within the required timeframe. The pass-through entity, Mecklenburg County, requires subrecipients to submit monthly expenditure and performance reports via email 15 days after each month end. For 2 months selected, the reports were not submitted within the required timeframe. For 3 months selected, the Organization was unable to provide evidence of submission. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Organization enhance its procedures to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions: To prevent further late reports, internal calendar notifications will be added to the Executive Director and Program Director’s calendars. The Director of Finance & Business will monitor status of report submissions. The Chief of Staff of the program will maintain adequate documentation of report submissions.
FINDING 2023-002 Federal Program Information: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Transitional Living for Homeless Youth (ALN 93.550) Basic Center Grant (ALN 93.623) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting: 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 (2 CFR 200.329 (c)(1)). Condition: For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Cause: Lack of administrative oversight in regard to periodic reporting. Effect or Potential Effect: The Organization was not in compliance with the reporting requirements. Questioned Costs: None. Context: The U.S. Department of Health and Human Services requires semi-annual federal financial reports be submitted into the HHS Payment Management System (PMS) and semi-annual performance progress reports be submitted into the GrantSolutions system 30 days after the end of the semi-annual period. For 2 semi-annual financial reports selected and 2 semi-annual performance report selected, the reports were not submitted within the required timeframe. The pass-through entity, Mecklenburg County, requires subrecipients to submit monthly expenditure and performance reports via email 15 days after each month end. For 2 months selected, the reports were not submitted within the required timeframe. For 3 months selected, the Organization was unable to provide evidence of submission. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Organization enhance its procedures to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions: To prevent further late reports, internal calendar notifications will be added to the Executive Director and Program Director’s calendars. The Director of Finance & Business will monitor status of report submissions. The Chief of Staff of the program will maintain adequate documentation of report submissions.
FINDING 2023-002 Federal Program Information: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Transitional Living for Homeless Youth (ALN 93.550) Basic Center Grant (ALN 93.623) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting: 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 (2 CFR 200.329 (c)(1)). Condition: For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Cause: Lack of administrative oversight in regard to periodic reporting. Effect or Potential Effect: The Organization was not in compliance with the reporting requirements. Questioned Costs: None. Context: The U.S. Department of Health and Human Services requires semi-annual federal financial reports be submitted into the HHS Payment Management System (PMS) and semi-annual performance progress reports be submitted into the GrantSolutions system 30 days after the end of the semi-annual period. For 2 semi-annual financial reports selected and 2 semi-annual performance report selected, the reports were not submitted within the required timeframe. The pass-through entity, Mecklenburg County, requires subrecipients to submit monthly expenditure and performance reports via email 15 days after each month end. For 2 months selected, the reports were not submitted within the required timeframe. For 3 months selected, the Organization was unable to provide evidence of submission. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Organization enhance its procedures to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions: To prevent further late reports, internal calendar notifications will be added to the Executive Director and Program Director’s calendars. The Director of Finance & Business will monitor status of report submissions. The Chief of Staff of the program will maintain adequate documentation of report submissions.
FINDING 2023-002 Federal Program Information: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Transitional Living for Homeless Youth (ALN 93.550) Basic Center Grant (ALN 93.623) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting: 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 (2 CFR 200.329 (c)(1)). Condition: For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Cause: Lack of administrative oversight in regard to periodic reporting. Effect or Potential Effect: The Organization was not in compliance with the reporting requirements. Questioned Costs: None. Context: The U.S. Department of Health and Human Services requires semi-annual federal financial reports be submitted into the HHS Payment Management System (PMS) and semi-annual performance progress reports be submitted into the GrantSolutions system 30 days after the end of the semi-annual period. For 2 semi-annual financial reports selected and 2 semi-annual performance report selected, the reports were not submitted within the required timeframe. The pass-through entity, Mecklenburg County, requires subrecipients to submit monthly expenditure and performance reports via email 15 days after each month end. For 2 months selected, the reports were not submitted within the required timeframe. For 3 months selected, the Organization was unable to provide evidence of submission. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Organization enhance its procedures to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions: To prevent further late reports, internal calendar notifications will be added to the Executive Director and Program Director’s calendars. The Director of Finance & Business will monitor status of report submissions. The Chief of Staff of the program will maintain adequate documentation of report submissions.
Compliance with Reporting Requirements Federal Agency: U.S. Department of Education Information on Federal Program: Client Assistance Program, Assistance Listing 84.161 Criteria: 2 CFR section 200.329 requires the submission of Federal Financial Report SF-425, annually. Statement of Condition: Our testing over financial reporting included the timely submission of the annual report during DRNY’s fiscal year-end. The annual report for Contract H161A220065 due October 31, 2022, was not filed until November 15, 2022. We also viewed the report for the FY23 grant, noting it was due October 31, 2023 and submitted October 10, 2023. Statement of Cause: There were some discrepancies in due dates for the annual SF-425 report listed between the grant award notice and the filing website. The filing website had noted in the language that annual reports were due 90 days after the fiscal year-end, in which case, DRNY would have been in compliance. Statement of Effect: Annual reports noted above were not filed within the required reporting deadline. Questioned Costs: None Perspective Information: As part of testing the compliance with the reporting requirements of the program, the submission of the annual SF-425, due within the period under audit, is reviewed for timeliness of submission. Identification of Repeat Finding: No Recommendation: Disability Rights New York should develop a tracking system for when their various grant reports are due based on the grant award notices to ensure timely filing of their annual reports. View of Responsible Officials and Corrective Action Plan: Since the late submissions in November 2022, DRNY has ensured that the SF425s were submitted in accordance with the due dates per the Grant Award notices (GANs). Further DRNY has now calendared within Outlook all the grant reporting requirements required for awards for the next year and created an Excel tracking sheet of all the remaining reporting required for current grants. Both the Executive Director and the CFO have access to this Excel tracking and the calendar invites. As new GANs are received, the CFO will calendar in the tracking document all reporting requirements and within Outlook send out invites each calendar year and copy the Executive Director on those calendar invites. CFO will confirm to Executive Director as these reports are complete and document in the Excel tracker. Danielle Myers, CFO, is responsible for the resolution of this corrective action plan by 3/1/2024.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Treasury Department Federal Financial Assistance Listing 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement – Reporting Material Weakness in Internal Control over Compliance Criteria: Non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly, except in unusual circumstances, using a form or format authorized by OMB (2 CFR section 200.329). They also may be required to submit special reports as required by the terms and conditions of the federal award. For the Coronavirus State and Local Fiscal Recovery Funds, the City is required to submit the Project and Expenditure Report quarterly. Condition: We noted that while the City submitted the reports as required, the reports contained errors including incorrect amounts and reporting information on the incorrect line items. Cause: The City did not have processes in place to ensure that amounts and information being reported to the Treasury contained accurate and complete information, and that the information being reported was on the correct line. Effect: The City submitted inaccurate reports to Treasury. While the City ultimately corrected the reports with their final annual report submission, the timing of the corrected report was outside the Treasury allowed timeframe of 60 days after the report. Questioned Costs: None reported. Context/Sampling: Sampling was not used as 100% of the reports that were required to be submitted were tested. Repeat Finding from Prior Year(s): No Recommendation: The City should review their current practices and procedures for federal compliance reporting to ensure that the information being reported is complete and accurate. Views of Responsible Officials: The City concurs with the auditor’s findings.
U.S. Treasury Department Federal Financial Assistance Listing 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement – Reporting Material Weakness in Internal Control over Compliance Criteria: Non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly, except in unusual circumstances, using a form or format authorized by OMB (2 CFR section 200.329). They also may be required to submit special reports as required by the terms and conditions of the federal award. For the Coronavirus State and Local Fiscal Recovery Funds, the City is required to submit the Project and Expenditure Report quarterly. Condition: We noted that while the City submitted the reports as required, the reports contained errors including incorrect amounts and reporting information on the incorrect line items. Cause: The City did not have processes in place to ensure that amounts and information being reported to the Treasury contained accurate and complete information, and that the information being reported was on the correct line. Effect: The City submitted inaccurate reports to Treasury. While the City ultimately corrected the reports with their final annual report submission, the timing of the corrected report was outside the Treasury allowed timeframe of 60 days after the report. Questioned Costs: None reported. Context/Sampling: Sampling was not used as 100% of the reports that were required to be submitted were tested. Repeat Finding from Prior Year(s): No Recommendation: The City should review their current practices and procedures for federal compliance reporting to ensure that the information being reported is complete and accurate. Views of Responsible Officials: The City concurs with the auditor’s findings.
Finding 2023-007 – Reporting (Significant Deficiency and Noncompliance) Information on the federal program: U.S. Department of Health and Human Services, Assistance Listing #93.137 Community Programs to Improve Minority Health Grant Program. Criteria: 2 CFR section 200.328 establishes the requirements for timely and accurate financial reporting requirements and 2 CFR 200.329 establishes responsibility for reporting activities under the grant. Both financial and programmatic reporting requires the nonfederal entity to establish internal controls to ensure accuracy of reports. Condition: We tested on financial and one programmatic report filed for this grant during the year. For the programmatic report, data reported for accomplishments and clients served was not clearly supported. In addition, review and approval of the report was not clearly documented. Cause: Results reported in the programmatic report were supported by time sheets and client internal notes. This support was not summarized or categorized in a manner in which the reported data could be traced back to the support. Employees involved in the preparing and filing of these reports are copied on email submission but a review and approval prior to submission was not documented. Effect: The Council did not comply with reporting control requirements. Questioned Costs: None reported Recommendation: We recommend the Council strengthen procedures and documentation policies to ensure program accomplishments are adequately supported by records that are accumulated and summarized in accordance with the required criteria. Procedures should also be strengthened to include a clear review and approval process to be documented prior to report submission. Views of Responsible Officials: See Management’s View and Corrective Action Plan at the end of the report.
Material Noncompliance 2023-004 Inaccurate amounts reported on annual performance report. Assistance Number 21.027 Federal Agency United States Treasury Pass-through None Questioned Cost None Repeat Finding No Criteria: Under 2 CFR 200.329, recipients must submit performance reports at the interval required by the federal awarding agency and ensure that such reports contain a comparison of actual accomplishments to the objectives of the award, along with sufficient information to evaluate performance. Condition: The auditee did not submit an accurate performance report to the federal awarding agency in accordance with the specified criteria in the grant agreement. Cause: A clerical error was made in the amounts reported on the required performance report. Effect: Incomplete performance reporting reduces the federal agency’s ability to evaluate program effectiveness and compliance with award objectives. Continued noncompliance may place the organization at risk for additional oversight, delayed funding, or other administrative actions. Recommendation: Management should ensure complete and accurate submission of performance reports. Views of Responsible: Officials The submission of the report was done timely and General Ledgers from the subject fiscal years were used in preparing the report. The County will ensure that information garnered from the General Ledgers coincide and accurately match future reports before submission.
2023-004 – Department of the Interior Federal Program Name: Natural Resource Stewardship - Pass-Through Agency: N/A Assistance Listing Number: 15.944 Federal Award Identification Year: 2023 Award Period: 10/01/2022 – 09/30/2023 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria: 2 CFR 200.328 - Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB approved, governmentwide data elements available from the OMB designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor= more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. 2 CFR 200.329(c)(1) -Requirements state that the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or passthrough entity to best inform improvements in program outcomes and productivity. Condition: For the reports submitted to the National Park Service, there was not documented review and approval of the submission by management. Context: Internal controls need to be formally documented as well as have support and authorization. With no authorization or proof that the internal control was completed, we cannot rely on the controls. Effect: Not having internal controls formalized and documented can lead to higher risk of noncompliance and misreporting. Cause: Internal controls are not formalized or documented. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that CIES modifies its internal control policies for general review and approval of the reporting requirements set forth by the criteria listed above. Management’s Views: See separate corrective action plan.
FEDERAL PROGRAM ALL FEDERAL PROGRAMS ON THE SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS AWARD NUMBERS ALL AWARDS COMPLIANCE REQUIREMENT ACTIVITIES ALLOWED OR UNALLOWED TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA Uniform Guidance at 2 CFR 200 §200.302, Financial Management, establishes that: “(a) Each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State's funds. All recipient and subrecipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. (See § 200.450). (b) The recipient's and subrecipient's financial management system must provide for the following (see §§ 200.334, 200.335, 200.336, and 200.337): (1) Identification of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number, year the Federal award was issued, and name of the Federal agency or pass-through entity. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. When a Federal agency or pass-through entity requires reporting on an accrual basis from a recipient or subrecipient that maintains its records other than on an accrual basis, the recipient or subrecipient must not be required to establish an accrual accounting system. This recipient or subrecipient may develop accrual data for its reports based on an analysis of the documentation on hand. (3) Maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. … (6) Written procedures to implement the requirements of § 200.305. (7) Written procedures for determining the allowability of costs in accordance with subpart E and the terms and conditions of the Federal award.” STATEMENT OF CONDITION As part of our understanding of internal controls and compliance testing regarding activities allowed or unallowed, we obtained a procedures manual. We found the following deficiencies: • The Center provided written internal control procedures over federal funds management. We observed that the policy didn’t include any detail of procedures, just a general requirement. In addition, the policy does not identify the personnel responsible for the processes to establish segregation of duties. • We selected a sample of 10 (number of disbursements selected) federal funds disbursed and noted that invoices are not marked as they are paid. • From the sample of federal funds disbursed, no evidence was found of approval or verification of allowability of the disbursement, proper segregation of duties, or accountability. • The Center lacks an adequate process to provide regular training to staff on Generally Accepted Government Auditing Standards, general documentation, acquisitions levels, formal agreements with vendors, vendor selections guidelines and best practices, required documentation regarding grant requirements and other internal best practices. QUESTIONED COSTS No questioned costs identified. PERSPECTIVE INFORMATION This is a systematic deficiency. After conducting personnel interviews, we were able to identify procedures for validating the payments. The person told us that after a need to purchase goods or services is identified by the centers, the entity Administrator requests authorization from the President. The President validates with the external accounting firm that the expense category is included in the approved budget and that funds are available before approving the payment. Procedures and internal controls manuals should provide for and ensure the segregation of duties. STATEMENT OF CAUSE The Center didn't have adequate internal controls in place, or documentation that presented adequate segregation of duties and compliance with applicable laws and regulations. In addition, no internal controls were documented that supported proper accountability of funds. POSSIBLE ASSERTED EFFECT The Center could incur in unallowable costs or activities and not be able to prevent or detect a transaction that doesn't comply with the Federal regulation. IDENTIFICATION OF REPEAT FINDING No reported as prior audit finding. RECOMMENDATIONS We recommend that management establish an adequate internal controls process that identifies documentation, personnel responsible and authorizations. In addition, we recommend management to update established written procedures and internal controls manuals to provide and document the segregation of duties related to the activities allowed or unallowed compliance requirement.
Finding Reference: 2023-003 – Reporting Federal Agency: U.S Department of Agriculture Federal Program: Water and Waste Disposal System for Rural Communities - ALN# 10.760 Compliance Requirement: Reporting Criteria: The Uniform Guidance requires that non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly, except in unusual circumstances, using a form or format authorized by OMB (2 CFR section 200.329). They also may be required to submit special reports as required by the terms and conditions of the federal award. The U.S Department of Agriculture requires the Authority to submit Quarterly Income and Expense Statements. The reports are to be signed by the appropriate borrower official and submitted within 30 days of each quarter’s end. Condition: The Authority has not submitted Quarterly Income and Expense Statements within 30 days of the fiscal quarter end. However, the Authority has submitted audited annual financial reports within 9 months of fiscal year end. Cause and Effect: The Authority was unacquainted with quarterly filing requirements as set forth by the U.S. Department of Agriculture per the loan agreement. Without filing quarterly Income and Expense Statements, USDA is unaware of how funding is spent throughout the year. Questioned Cost: None Identification of Repeat Finding: No Recommendation: The Authority should begin to submit quarterly reports in accordance with loan agreement. Views of Responsible Officials: This was first brought to the Authority’s attention in the current year. The Authority is working towards submitting appropriate reports.