Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2023-014 – Noncompliance with Reporting Requirements Over Federal Grant – Coronavirus State and Local Fiscal Recovery Funds (Repeat Finding – 2022-014) PASS-THROUGH GRANTOR: Direct Grant FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Reporting QUESTIONED COSTS: $0 Condition: In the review of fifty-five (55) expenditures for federal programs, five (5) instances were noted where the expenditures were not correctly reported on the Coronavirus State and Local Fiscal Recovery Funds compliance reports. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are properly reported in accordance with federal compliance requirements. Effect of Condition: This condition could result in noncompliance to grant requirements. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. Management Response: Chairman of the Board of County Commissioners: The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants. Criteria: Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (10. Reporting.) reads as follows: 10. Reporting. All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, your organization needs to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. See Part 2 of this guidance for a full overview of recipient reporting responsibilities. Further, 2 CFR § 200.329 Monitoring and Reporting Program Performance (c)(1) reads as follows: 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. Intervals must be no less frequent than annually nor more frequent 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. 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. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance reports as required by the terms and conditions of the Federal award. See also § 200.344. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report.
FINDING 2023-002 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context The School Corporation was required to submit an annual data report to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditure, and expenditures per activity. During the audit period, the School Corporation submitted one ESSER I report, one ESSER II report, and one ESSER III report, for a total of three reports. The annual data reports were prepared by the Director of Grants and reviewed by the Chief Academic Officer; however, this process did not allow for the prevention, or detection and corrections, of errors prior to submission. Due to the lack of effective internal controls, one of the three annual data reports was not supported by the School Corporation's records. For the ESSER III report, which covered the period of July 1, 2021 to June 30, 2022, total expenses per the report were $6,026,425. However, the ledger had total expenses for the award, for that period, of $6,686,286. The lack of effective internal controls and noncompliance were isolated to the ESSER III report. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . INDIANA STATE BOARD OF ACCOUNTS 21 METROPOLITAN SCHOOL DISTRICT OF LAWRENCE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporations management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III report was not supported by the School Corporation's records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding by the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and strengthen its policies and procedures to ensure all reports submitted on behalf of the Education Stabilization Fund program funds are accurate. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2023-002 - Source Documentation (Significant Deficiency) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management CFDA Title and Number: 20.509 (5311) CARES 5311 Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the fi-nancial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: The District prepared reimbursement calculations according to an internally developed spreadsheet tool, rather than using amounts directly obtained from the general ledger and supporting documentation Cause: General ledger data used to prepare spreadsheets, then used to complete reimbursement requests added unnecessary complexity and potential for errors in the reimbursement and request and grant reporting process. Internal control procedures assuring accurate and timely review of reports and filing of the reimbursement re-quests were not designed or implemented. Effect or Potential Effect: The lack of effective internal control activities over financial reporting could allow for inadvertent errors, such as calculation errors, payments for unauthorized purposes, and result in improper grant accounting, reporting, and reimbursement. Questioned Cost: No Context: Internal disputes regarding grant reimbursement request procedures were evident. The weak or nonex-istent controls over the reimbursement request procedures created a potential for inaccurate, incomplete report-ing. Repeat of a Prior-Year Finding: Yes, Findings and Questioned Costs 2022-003 Recommendation: The District should continue to improve grant accounting efforts, and establish a more simplified and effective process for the review and approval of grant accounting and reimbursement requests. Additional training of management should occur to ensure they fully understand all compliance regulations and have the skills to assist in designing and implementing effective controls. Monitoring of the control procedures related to the grant accounting and reimbursement request should be performed regularly to ensure reports are filed accurately and timely. Information and communication regarding identified weaknesses and opportunities to improve the policies and procedures should occur among management and the individual performing the monitoring of the procedures. District's Response: The District’s Finance Manager and District Manager are working towards using general ledger reporting exclusively for reimbursement request reporting. General ledger activity became more timely as improvements were implemented based on prior year findings. Management acknowledges delays in that pro-cess that continued as a result, to some extent, of the use of the self-developed spreadsheet reports then used for completing grant reimbursement requests. Corrective Action Plan: The District’s Finance Manager will continue to make improvements in general ledg-er recording and reporting systems so that those reports can then be used without intermediary report methods to prepare reimbursement request forms. Review of the reimbursement requests will take place within data re-ports generated directly from the general ledger. The district will engage an individual or firm to ensure that the timing and overall processes related to grant reimbursement and reporting does not result in reporting errors or omissions. . Planned Implementation Date: September 30, 2024 Responsible Person: General Manager, Umpqua Public Transit District
Finding 2023-002 - Source Documentation (Significant Deficiency) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management CFDA Title and Number: 20.509 (5311) CARES 5311 Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the fi-nancial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: The District prepared reimbursement calculations according to an internally developed spreadsheet tool, rather than using amounts directly obtained from the general ledger and supporting documentation Cause: General ledger data used to prepare spreadsheets, then used to complete reimbursement requests added unnecessary complexity and potential for errors in the reimbursement and request and grant reporting process. Internal control procedures assuring accurate and timely review of reports and filing of the reimbursement re-quests were not designed or implemented. Effect or Potential Effect: The lack of effective internal control activities over financial reporting could allow for inadvertent errors, such as calculation errors, payments for unauthorized purposes, and result in improper grant accounting, reporting, and reimbursement. Questioned Cost: No Context: Internal disputes regarding grant reimbursement request procedures were evident. The weak or nonex-istent controls over the reimbursement request procedures created a potential for inaccurate, incomplete report-ing. Repeat of a Prior-Year Finding: Yes, Findings and Questioned Costs 2022-003 Recommendation: The District should continue to improve grant accounting efforts, and establish a more simplified and effective process for the review and approval of grant accounting and reimbursement requests. Additional training of management should occur to ensure they fully understand all compliance regulations and have the skills to assist in designing and implementing effective controls. Monitoring of the control procedures related to the grant accounting and reimbursement request should be performed regularly to ensure reports are filed accurately and timely. Information and communication regarding identified weaknesses and opportunities to improve the policies and procedures should occur among management and the individual performing the monitoring of the procedures. District's Response: The District’s Finance Manager and District Manager are working towards using general ledger reporting exclusively for reimbursement request reporting. General ledger activity became more timely as improvements were implemented based on prior year findings. Management acknowledges delays in that pro-cess that continued as a result, to some extent, of the use of the self-developed spreadsheet reports then used for completing grant reimbursement requests. Corrective Action Plan: The District’s Finance Manager will continue to make improvements in general ledg-er recording and reporting systems so that those reports can then be used without intermediary report methods to prepare reimbursement request forms. Review of the reimbursement requests will take place within data re-ports generated directly from the general ledger. The district will engage an individual or firm to ensure that the timing and overall processes related to grant reimbursement and reporting does not result in reporting errors or omissions. . Planned Implementation Date: September 30, 2024 Responsible Person: General Manager, Umpqua Public Transit District
Finding 2023-002 - Source Documentation (Significant Deficiency) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management CFDA Title and Number: 20.509 (5311) CARES 5311 Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the fi-nancial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: The District prepared reimbursement calculations according to an internally developed spreadsheet tool, rather than using amounts directly obtained from the general ledger and supporting documentation Cause: General ledger data used to prepare spreadsheets, then used to complete reimbursement requests added unnecessary complexity and potential for errors in the reimbursement and request and grant reporting process. Internal control procedures assuring accurate and timely review of reports and filing of the reimbursement re-quests were not designed or implemented. Effect or Potential Effect: The lack of effective internal control activities over financial reporting could allow for inadvertent errors, such as calculation errors, payments for unauthorized purposes, and result in improper grant accounting, reporting, and reimbursement. Questioned Cost: No Context: Internal disputes regarding grant reimbursement request procedures were evident. The weak or nonex-istent controls over the reimbursement request procedures created a potential for inaccurate, incomplete report-ing. Repeat of a Prior-Year Finding: Yes, Findings and Questioned Costs 2022-003 Recommendation: The District should continue to improve grant accounting efforts, and establish a more simplified and effective process for the review and approval of grant accounting and reimbursement requests. Additional training of management should occur to ensure they fully understand all compliance regulations and have the skills to assist in designing and implementing effective controls. Monitoring of the control procedures related to the grant accounting and reimbursement request should be performed regularly to ensure reports are filed accurately and timely. Information and communication regarding identified weaknesses and opportunities to improve the policies and procedures should occur among management and the individual performing the monitoring of the procedures. District's Response: The District’s Finance Manager and District Manager are working towards using general ledger reporting exclusively for reimbursement request reporting. General ledger activity became more timely as improvements were implemented based on prior year findings. Management acknowledges delays in that pro-cess that continued as a result, to some extent, of the use of the self-developed spreadsheet reports then used for completing grant reimbursement requests. Corrective Action Plan: The District’s Finance Manager will continue to make improvements in general ledg-er recording and reporting systems so that those reports can then be used without intermediary report methods to prepare reimbursement request forms. Review of the reimbursement requests will take place within data re-ports generated directly from the general ledger. The district will engage an individual or firm to ensure that the timing and overall processes related to grant reimbursement and reporting does not result in reporting errors or omissions. . Planned Implementation Date: September 30, 2024 Responsible Person: General Manager, Umpqua Public Transit District
Finding 2023-002 - Source Documentation (Significant Deficiency) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management CFDA Title and Number: 20.509 (5311) CARES 5311 Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the fi-nancial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: The District prepared reimbursement calculations according to an internally developed spreadsheet tool, rather than using amounts directly obtained from the general ledger and supporting documentation Cause: General ledger data used to prepare spreadsheets, then used to complete reimbursement requests added unnecessary complexity and potential for errors in the reimbursement and request and grant reporting process. Internal control procedures assuring accurate and timely review of reports and filing of the reimbursement re-quests were not designed or implemented. Effect or Potential Effect: The lack of effective internal control activities over financial reporting could allow for inadvertent errors, such as calculation errors, payments for unauthorized purposes, and result in improper grant accounting, reporting, and reimbursement. Questioned Cost: No Context: Internal disputes regarding grant reimbursement request procedures were evident. The weak or nonex-istent controls over the reimbursement request procedures created a potential for inaccurate, incomplete report-ing. Repeat of a Prior-Year Finding: Yes, Findings and Questioned Costs 2022-003 Recommendation: The District should continue to improve grant accounting efforts, and establish a more simplified and effective process for the review and approval of grant accounting and reimbursement requests. Additional training of management should occur to ensure they fully understand all compliance regulations and have the skills to assist in designing and implementing effective controls. Monitoring of the control procedures related to the grant accounting and reimbursement request should be performed regularly to ensure reports are filed accurately and timely. Information and communication regarding identified weaknesses and opportunities to improve the policies and procedures should occur among management and the individual performing the monitoring of the procedures. District's Response: The District’s Finance Manager and District Manager are working towards using general ledger reporting exclusively for reimbursement request reporting. General ledger activity became more timely as improvements were implemented based on prior year findings. Management acknowledges delays in that pro-cess that continued as a result, to some extent, of the use of the self-developed spreadsheet reports then used for completing grant reimbursement requests. Corrective Action Plan: The District’s Finance Manager will continue to make improvements in general ledg-er recording and reporting systems so that those reports can then be used without intermediary report methods to prepare reimbursement request forms. Review of the reimbursement requests will take place within data re-ports generated directly from the general ledger. The district will engage an individual or firm to ensure that the timing and overall processes related to grant reimbursement and reporting does not result in reporting errors or omissions. . Planned Implementation Date: September 30, 2024 Responsible Person: General Manager, Umpqua Public Transit District
Finding 2023-002 - Source Documentation (Significant Deficiency) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management CFDA Title and Number: 20.509 (5311) CARES 5311 Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the fi-nancial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: The District prepared reimbursement calculations according to an internally developed spreadsheet tool, rather than using amounts directly obtained from the general ledger and supporting documentation Cause: General ledger data used to prepare spreadsheets, then used to complete reimbursement requests added unnecessary complexity and potential for errors in the reimbursement and request and grant reporting process. Internal control procedures assuring accurate and timely review of reports and filing of the reimbursement re-quests were not designed or implemented. Effect or Potential Effect: The lack of effective internal control activities over financial reporting could allow for inadvertent errors, such as calculation errors, payments for unauthorized purposes, and result in improper grant accounting, reporting, and reimbursement. Questioned Cost: No Context: Internal disputes regarding grant reimbursement request procedures were evident. The weak or nonex-istent controls over the reimbursement request procedures created a potential for inaccurate, incomplete report-ing. Repeat of a Prior-Year Finding: Yes, Findings and Questioned Costs 2022-003 Recommendation: The District should continue to improve grant accounting efforts, and establish a more simplified and effective process for the review and approval of grant accounting and reimbursement requests. Additional training of management should occur to ensure they fully understand all compliance regulations and have the skills to assist in designing and implementing effective controls. Monitoring of the control procedures related to the grant accounting and reimbursement request should be performed regularly to ensure reports are filed accurately and timely. Information and communication regarding identified weaknesses and opportunities to improve the policies and procedures should occur among management and the individual performing the monitoring of the procedures. District's Response: The District’s Finance Manager and District Manager are working towards using general ledger reporting exclusively for reimbursement request reporting. General ledger activity became more timely as improvements were implemented based on prior year findings. Management acknowledges delays in that pro-cess that continued as a result, to some extent, of the use of the self-developed spreadsheet reports then used for completing grant reimbursement requests. Corrective Action Plan: The District’s Finance Manager will continue to make improvements in general ledg-er recording and reporting systems so that those reports can then be used without intermediary report methods to prepare reimbursement request forms. Review of the reimbursement requests will take place within data re-ports generated directly from the general ledger. The district will engage an individual or firm to ensure that the timing and overall processes related to grant reimbursement and reporting does not result in reporting errors or omissions. . Planned Implementation Date: September 30, 2024 Responsible Person: General Manager, Umpqua Public Transit District
Finding 2023-002 - Source Documentation (Significant Deficiency) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management CFDA Title and Number: 20.509 (5311) CARES 5311 Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the fi-nancial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: The District prepared reimbursement calculations according to an internally developed spreadsheet tool, rather than using amounts directly obtained from the general ledger and supporting documentation Cause: General ledger data used to prepare spreadsheets, then used to complete reimbursement requests added unnecessary complexity and potential for errors in the reimbursement and request and grant reporting process. Internal control procedures assuring accurate and timely review of reports and filing of the reimbursement re-quests were not designed or implemented. Effect or Potential Effect: The lack of effective internal control activities over financial reporting could allow for inadvertent errors, such as calculation errors, payments for unauthorized purposes, and result in improper grant accounting, reporting, and reimbursement. Questioned Cost: No Context: Internal disputes regarding grant reimbursement request procedures were evident. The weak or nonex-istent controls over the reimbursement request procedures created a potential for inaccurate, incomplete report-ing. Repeat of a Prior-Year Finding: Yes, Findings and Questioned Costs 2022-003 Recommendation: The District should continue to improve grant accounting efforts, and establish a more simplified and effective process for the review and approval of grant accounting and reimbursement requests. Additional training of management should occur to ensure they fully understand all compliance regulations and have the skills to assist in designing and implementing effective controls. Monitoring of the control procedures related to the grant accounting and reimbursement request should be performed regularly to ensure reports are filed accurately and timely. Information and communication regarding identified weaknesses and opportunities to improve the policies and procedures should occur among management and the individual performing the monitoring of the procedures. District's Response: The District’s Finance Manager and District Manager are working towards using general ledger reporting exclusively for reimbursement request reporting. General ledger activity became more timely as improvements were implemented based on prior year findings. Management acknowledges delays in that pro-cess that continued as a result, to some extent, of the use of the self-developed spreadsheet reports then used for completing grant reimbursement requests. Corrective Action Plan: The District’s Finance Manager will continue to make improvements in general ledg-er recording and reporting systems so that those reports can then be used without intermediary report methods to prepare reimbursement request forms. Review of the reimbursement requests will take place within data re-ports generated directly from the general ledger. The district will engage an individual or firm to ensure that the timing and overall processes related to grant reimbursement and reporting does not result in reporting errors or omissions. . Planned Implementation Date: September 30, 2024 Responsible Person: General Manager, Umpqua Public Transit District
Finding 2023-002 - Source Documentation (Significant Deficiency) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management CFDA Title and Number: 20.509 (5311) CARES 5311 Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the fi-nancial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: The District prepared reimbursement calculations according to an internally developed spreadsheet tool, rather than using amounts directly obtained from the general ledger and supporting documentation Cause: General ledger data used to prepare spreadsheets, then used to complete reimbursement requests added unnecessary complexity and potential for errors in the reimbursement and request and grant reporting process. Internal control procedures assuring accurate and timely review of reports and filing of the reimbursement re-quests were not designed or implemented. Effect or Potential Effect: The lack of effective internal control activities over financial reporting could allow for inadvertent errors, such as calculation errors, payments for unauthorized purposes, and result in improper grant accounting, reporting, and reimbursement. Questioned Cost: No Context: Internal disputes regarding grant reimbursement request procedures were evident. The weak or nonex-istent controls over the reimbursement request procedures created a potential for inaccurate, incomplete report-ing. Repeat of a Prior-Year Finding: Yes, Findings and Questioned Costs 2022-003 Recommendation: The District should continue to improve grant accounting efforts, and establish a more simplified and effective process for the review and approval of grant accounting and reimbursement requests. Additional training of management should occur to ensure they fully understand all compliance regulations and have the skills to assist in designing and implementing effective controls. Monitoring of the control procedures related to the grant accounting and reimbursement request should be performed regularly to ensure reports are filed accurately and timely. Information and communication regarding identified weaknesses and opportunities to improve the policies and procedures should occur among management and the individual performing the monitoring of the procedures. District's Response: The District’s Finance Manager and District Manager are working towards using general ledger reporting exclusively for reimbursement request reporting. General ledger activity became more timely as improvements were implemented based on prior year findings. Management acknowledges delays in that pro-cess that continued as a result, to some extent, of the use of the self-developed spreadsheet reports then used for completing grant reimbursement requests. Corrective Action Plan: The District’s Finance Manager will continue to make improvements in general ledg-er recording and reporting systems so that those reports can then be used without intermediary report methods to prepare reimbursement request forms. Review of the reimbursement requests will take place within data re-ports generated directly from the general ledger. The district will engage an individual or firm to ensure that the timing and overall processes related to grant reimbursement and reporting does not result in reporting errors or omissions. . Planned Implementation Date: September 30, 2024 Responsible Person: General Manager, Umpqua Public Transit District
Finding Reference 2023-005 Federal Agency: U.S. Department of Homeland Security Pass-Through Agency: Central Office of Recovery, Reconstruction and Resiliency of Puerto Rico (COR3) Program: Disaster Grants – Public Assistance (Presidentially Declared Disaster) (ALN 97.036) Compliance Requirement: Reporting (L) Type of Finding: Significant Deficiency in Internal Controls (SD), Instance of Noncompliance (NC) Statement of Condition In our Reporting Test, we evaluated the Quarterly Progress Reports of a total of nine (9) projects for two quarters of fiscal year 2022-2023. During our audit procedures, we noted that the reports did not agree with the accounting and project records. Criteria 2 CFR 200.302 (a) stated that the state’s and the other non-Federal entity’s financial management system, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Also, 2 CFR 200.302 (b) (2) states that the financial management system of each non-Federal entity must provide accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. Cause of Condition The Municipality accounting controls and procedures fail to ensure accurate, current and complete disclosure of the financial results of federal assisted activities. Effect of Condition The expenses reported in the Quarterly Progress Reports do not agree with the accounting records. Recommendation We recommend that Program Administrators to reconcile the differences between the quarterly report and the accounting records before the submission of the next submission to the pass-through entity. Questioned Cost None Prior Year Finding No Views of Responsible Officials and Planned Corrective Action We concur with the finding. Quarterly Progress Reports for large projects will be prospectively adjusted to reflect expenditures incurred over the reporting period Implementation Date: March 31, 2025 Responsible Person: Belinda Álvarez Finance Director
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “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 outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022-013 – Lack of Internal Controls and Noncompliance with Reporting Requirements Over Federal Grant Coronavirus State and Local Fiscal Recovery Funds (Repeat Finding – 2022-013) PASS-THROUGH GRANTOR: Direct Grant FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Reporting QUESTIONED COSTS: $-0- Condition: The County has not established internal controls to ensure the correct expenditure category is used for reporting payments to the grant administrative contractor. The quarterly reports improperly classified payments totaling $177,465 to a contractor as a ‘Revenue Replacement’ expense instead of using the ‘Administrative’ expense category. Also, the quarterly reports improperly classified payments totaling $386,056 for the Resurrection House as a ‘Revenue Replacement’ expense instead of using the ‘Negative Economic Impact’ expense category as stated in the agreement with the Board of County Commissioners. This entity was also not reflected as a Beneficiary in the quarterly reports. Further, subrecipient agreements for the following pass-through entities were signed and approved by the Board of County Commissioners; however, the entities were not reported as subrecipients in the quarterly reports: • Grady County Fairgrounds • Town of Rush Springs • Grady County Rural Water #2 • Grady County Rural Water #6 Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with federal compliance requirements. Effect of Condition: This condition resulted in noncompliance to grant requirements. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. Management Response: Chairman of the Board of County Commissioners: The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants. Criteria: Accountability and stewardship should be overall goals in management’s accounting of federal funds. Internal controls should be designed to monitor compliance with laws and regulations pertaining to grant contracts. Title 2 CFR § 200.303(a) Internal Controls reads (a) reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Controls Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (10. Reporting.) reads as follows: All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, you organization needs to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Further, 2 CFR § 200.329 Monitoring and Reporting Program Performance (c)(1) reads as follows: 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. Intervals must be no less frequent than annually nor more frequent 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. 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. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance reports as required by the terms and conditions of the Federal award. See also § 200.344. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report.
FINDING 2023-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013, S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include proper segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by one employee without documentation to support an oversight or review process to prevent, or detect and correct, errors. In addition, the School Corporation was unable to provide supporting documentation for any of the information contained in the six reports submitted during the audit period. Ledgers and reimbursement requests were used to verify the information in three of the six reports; however, the other three reports could not be substantiated. The following errors were noted: The ESSER II, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 1 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the three reports noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Additionally, key line items were not supported by the records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013, S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include proper segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by one employee without documentation to support an oversight or review process to prevent, or detect and correct, errors. In addition, the School Corporation was unable to provide supporting documentation for any of the information contained in the six reports submitted during the audit period. Ledgers and reimbursement requests were used to verify the information in three of the six reports; however, the other three reports could not be substantiated. The following errors were noted: The ESSER II, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 1 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the three reports noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Additionally, key line items were not supported by the records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013, S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include proper segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by one employee without documentation to support an oversight or review process to prevent, or detect and correct, errors. In addition, the School Corporation was unable to provide supporting documentation for any of the information contained in the six reports submitted during the audit period. Ledgers and reimbursement requests were used to verify the information in three of the six reports; however, the other three reports could not be substantiated. The following errors were noted: The ESSER II, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 1 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the three reports noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Additionally, key line items were not supported by the records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013, S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include proper segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by one employee without documentation to support an oversight or review process to prevent, or detect and correct, errors. In addition, the School Corporation was unable to provide supporting documentation for any of the information contained in the six reports submitted during the audit period. Ledgers and reimbursement requests were used to verify the information in three of the six reports; however, the other three reports could not be substantiated. The following errors were noted: The ESSER II, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 1 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the three reports noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Additionally, key line items were not supported by the records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.