FINDING 2022-003 Subject: Water and Waste Disposal Systems for Rural Communities - Reporting Federal Agency: Department of Agriculture Federal Program: Water and Waste Disposal Systems for Rural Communities Assistance Listings Number: 10.760 Federal Award Number and Year (or Other Identifying Number): CY 2020 Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2021-004. Condition and Context The Town had not designed or implemented adequate internal controls and procedures to ensure that reports were prepared, accurate, and submitted in accordance with the applicable compliance requirements for the federal grant. The United States Department of Agriculture (USDA) requires the following two financial reports be submitted annually: 1. Statement of Budget, Income and Equity, (Form RD 442-2) 2. Balance Sheet (Form RD 442-3) The Form RD 442-2 covers financial operations relating to the borrower's water or waste disposal project. The Form RD 442-3 presents the financial status of the borrower's water or waste disposal project. In both instances, a borrower may submit the financial data on other forms, provided the forms are in a similar format and signed and dated by the organization's official to certify the correctness of the information. Alternatively, an annual audit may be submitted in lieu of the forms. The Town was required to file each report, as noted above, during the audit period. Both reports were selected for testing. Per inquiry with the Town and review of its records, the Town attempted to prepare Form RD 442-2; however, the report was never completed, nor was it filed with the appropriate authorities. Additionally, the Town did not file or even attempt to prepare Form RD 442-3. Neither alternative reports nor a financial statement were submitted to the USDA in lieu of the forms. The lack of internal controls and noncompliance were systemic issues, which occurred throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . ." 7 CFR 1780.47 states in part: "Borrower accounting methods, management reporting and audits. . . . (e) Borrowers exempt from audits. All borrowers who are exempt from audits, will, within 60 days following the end of each fiscal year, furnish the RUS with annual financial statements, consisting of a verification of the organization's balance sheet and statement of income and expense by an appropriate official of the organization. Forms RD 442-2, 'Statement of Budget, Income and Equity,' and 442-3 may be used. (f) Management reports. These reports will furnish management with a means of evaluating prior decisions and serve as a basis for planning future operations and financial strategies. In those cases where revenues from multiple sources are pledged as security for an RUS loan, two reports will be required; one for the project being financed by RUS and one combining the entire operation of the borrower. In those cases where RUS loans are secured by general obligation bonds or assessments and the borrower combines revenues from all sources, one management report combining all such revenues is acceptable. The following management data will be submitted by the borrower to the processing office. These reports at a minimum will include a balance sheet and income and expense statement. . . . (2) Annual management reports. Prior to the beginning of each fiscal year the following will be submitted to the processing office. (If Form RD 442-2 is used as the annual management report, enter data in column three only of Schedule 1, and complete all of Schedule 2.) (i) Two copies of the management reports and proposed 'Annual Budget.' (ii) Financial information may be reported on Form RD 442-2 which includes Schedule 1, 'Statement of Budget, Income and Equity' and Schedule 2, 'Projected Cash Flow' or information in similar format. (iii) A copy of the rate schedule in effect at the time of submission. (g) Substitute for management reports. When RUS loans are secured by the general obligation of the public body or tax assessments which total 100 percent of the debt service requirements, the State program official may authorize an annual audit to substitute for other management reports if the audit is received within nine months after the end of the audit period." Cause A proper system of internal controls was not designed by management of the Town. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the Town'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, required reports were not filed with the USDA. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the Town. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the Town establish a proper system of internal controls and develop policies and procedures to ensure required reports, or allowable alternatives are completed and filed with the USDA. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-007 Subject: CDBG - Entitlement Grants Cluster - Reporting Federal Agency: Department of Housing and Urban Development Federal Programs: Community Development Block Grants/Entitlement Grants, COVID-19 - Community Development Block Grants/Entitlement Grants Assistance Listings Number: 14.218 Federal Award Numbers and Years (or Other Identifying Numbers): B-19-MC-18-0015, B-20-MC-20-0015, B-20-MW-18-0015, B-21-MC-18-0015, B-22-MC-18-0015 Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2021-004. Condition and Context Financial Reporting For each CDBG award, the City is required to submit financial reports to Housing and Urban Development (HUD). The financial reports to be submitted are a quarterly CDBG Cash on Hand (PR29) report and an annual CDBG Financial Summary (PR26). The Community Development Specialist prepared the annual PR26 and quarterly PR29 reports without evidence of a review or an approval process to ensure accuracy of the reports submitted. During the audit period, there were three PR26 reports and six PR29 reports due. Four reports were selected for testing, two PR26 reports and two PR29 reports. One of the two PR26 reports was not supported by the City's records, and one of the two PR29 reports contained errors when reporting cash on hand. Performance Reporting The City is required to enter HUD 60002, Section 3 Summary Report, Economic Opportunities for Low- and Very Low-Income Persons report (Section 3) activities on the closeout screens in the Integrated Disbursement and Information System (IDIS), as well as within the Consolidated Annual Performance and Evaluation Report (CAPER). The Section 3 report was not submitted on the closeout screens in the IDIS as part of the closeout process. The City did submit the Section 3 information within the CAPER; however, the Section 3 information was not supported by the City's records. The City was not able to provide documentation supporting the Section 3 information in the CAPER. Special Reporting for Federal Funding Accountability and Transparency Act (FFATA) Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act), recipients (i.e., direct recipients) of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through the FSRS. INDIANA STATE BOARD OF ACCOUNTS 28 CITY OF ELKHART SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) There were two subawards that required submission in the FSRS during the audit period. The due date for the information was August 31, 2022, and November 30, 2022, respectively. The information was completed and submitted by the City; however, there was no documentation of the review or oversight process in place to ensure the accuracy of the information submitted. (See Report PDF for Schedule.) The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 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. . . ." Cause A proper system of internal controls was not designed by management of the City. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the City'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, required reports were not accurate nor submitted timely. 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 City. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the City design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure required reports are submitted timely and accurately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-007 Subject: CDBG - Entitlement Grants Cluster - Reporting Federal Agency: Department of Housing and Urban Development Federal Programs: Community Development Block Grants/Entitlement Grants, COVID-19 - Community Development Block Grants/Entitlement Grants Assistance Listings Number: 14.218 Federal Award Numbers and Years (or Other Identifying Numbers): B-19-MC-18-0015, B-20-MC-20-0015, B-20-MW-18-0015, B-21-MC-18-0015, B-22-MC-18-0015 Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2021-004. Condition and Context Financial Reporting For each CDBG award, the City is required to submit financial reports to Housing and Urban Development (HUD). The financial reports to be submitted are a quarterly CDBG Cash on Hand (PR29) report and an annual CDBG Financial Summary (PR26). The Community Development Specialist prepared the annual PR26 and quarterly PR29 reports without evidence of a review or an approval process to ensure accuracy of the reports submitted. During the audit period, there were three PR26 reports and six PR29 reports due. Four reports were selected for testing, two PR26 reports and two PR29 reports. One of the two PR26 reports was not supported by the City's records, and one of the two PR29 reports contained errors when reporting cash on hand. Performance Reporting The City is required to enter HUD 60002, Section 3 Summary Report, Economic Opportunities for Low- and Very Low-Income Persons report (Section 3) activities on the closeout screens in the Integrated Disbursement and Information System (IDIS), as well as within the Consolidated Annual Performance and Evaluation Report (CAPER). The Section 3 report was not submitted on the closeout screens in the IDIS as part of the closeout process. The City did submit the Section 3 information within the CAPER; however, the Section 3 information was not supported by the City's records. The City was not able to provide documentation supporting the Section 3 information in the CAPER. Special Reporting for Federal Funding Accountability and Transparency Act (FFATA) Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act), recipients (i.e., direct recipients) of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through the FSRS. INDIANA STATE BOARD OF ACCOUNTS 28 CITY OF ELKHART SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) There were two subawards that required submission in the FSRS during the audit period. The due date for the information was August 31, 2022, and November 30, 2022, respectively. The information was completed and submitted by the City; however, there was no documentation of the review or oversight process in place to ensure the accuracy of the information submitted. (See Report PDF for Schedule.) The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 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. . . ." Cause A proper system of internal controls was not designed by management of the City. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the City'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, required reports were not accurate nor submitted timely. 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 City. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the City design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure required reports are submitted timely and accurately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Ref. No. Compliance and Internal Control over Compliance Findings 2022-001 Reporting - Significant Deficiency Federal Agency: Department of Health and Human Services Pass-Through Entity: State of Hawaii Department of Human Services Assistance Listing No.: 93.558 Program: Temporary Assistance for Needy Families (TANF) Criteria: Uniform Guidance 2 CFR 200.329(c)(1) states that the non-Federal entity must submit performance repots at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. The sub-recipient agreement entered into with the State of Hawaii Department of Human Services required that a quarterly Maintenance of Effort (MOE) Expenditure Report be submitted no later than thirty (3) calendar days following the end of each quarter. Condition: During our audit, we noted two (2) quarters reviewed where the quarterly MOE was submitted more than 30 days after the quarter end. Cause: Lack of adherence to reporting requirements exhibited by key accounting personnel. Effect: Without an effective internal control system, untimely reporting could result in the misrepresentation of data and could adversely affect program outcomes and future funding. Recommendation The Organization should improve processes and procedures to ensure that quarterly reports required by the pass-through entity are completed and submitted on a timely basis. Views of Responsible Officials and Planned Corrective Action The Organization agrees with the finding and the recommendation. See Part IV Correction Action Plan.
#2022-009 - Major Federal Award Finding - Reporting Nature of Finding: Compliance Finding - Reporting and Material Weakness in Internal Controls Over Compliance Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing that no review procedures are in place surrounding these reports. Cause/Context: Controls were not in place to ensure accurate reporting. Only one individual was involved in the reporting process. Of the two reports tested, one Federal Status Report included an expenditure reported in an inaccurate budget category. Payroll tax costs were divided between the Fringe Benefits/Payroll tax budget line and the Other Expenses line, with a total of $1,554 reported in the incorrect budget category. Additionally, the client failed to identify that submission of a single audit was an applicable reporting requirement for the December 31, 2022 year, resulting in a late single audit filing. Effect: The lack of controls resulted in inaccurate, late, and failed reporting compliance. Recommendation: We recommend that a full-range of controls related to reporting, including federal program reporting be implemented. The Organization should devote the resources necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval should be documented and that documentation be maintained. Views of Responsible Officials and Planned Corrective Actions: MARR will retain a CPA consultant to implement a full-range of controls relating to reporting, including federal program reporting. MARR will take such steps as necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval will be documented in such documentation to be maintained.
#2022-009 - Major Federal Award Finding - Reporting Nature of Finding: Compliance Finding - Reporting and Material Weakness in Internal Controls Over Compliance Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing that no review procedures are in place surrounding these reports. Cause/Context: Controls were not in place to ensure accurate reporting. Only one individual was involved in the reporting process. Of the two reports tested, one Federal Status Report included an expenditure reported in an inaccurate budget category. Payroll tax costs were divided between the Fringe Benefits/Payroll tax budget line and the Other Expenses line, with a total of $1,554 reported in the incorrect budget category. Additionally, the client failed to identify that submission of a single audit was an applicable reporting requirement for the December 31, 2022 year, resulting in a late single audit filing. Effect: The lack of controls resulted in inaccurate, late, and failed reporting compliance. Recommendation: We recommend that a full-range of controls related to reporting, including federal program reporting be implemented. The Organization should devote the resources necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval should be documented and that documentation be maintained. Views of Responsible Officials and Planned Corrective Actions: MARR will retain a CPA consultant to implement a full-range of controls relating to reporting, including federal program reporting. MARR will take such steps as necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval will be documented in such documentation to be maintained.
2022-006 – Reporting Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: § 200.329 indicates that the non-federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Condition: There were two instances in which documentation was not available to support amounts included within reports submitted. These instances affected the Federal Financial Report and the UDS report. Questioned costs: None. Context: Documentation was not available to support the amount reported on line E, Federal share of expenditures, of the ARPA Federal Financial Report. In addition, there was no documentation to support two key lines items of the UDS report, Table 9E, Lines 1g and 1q, Column A. Cause: Management turnover Effect: Inaccurate reports could be file if there is no underlying documentation to support the amounts reported. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-07. Recommendation: We recommend that the Organization maintain supporting documentation for all reports required to be filed to the federal agency. Views of responsible officials: There is no disagreement with the audit finding.
2022-006 – Reporting Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: § 200.329 indicates that the non-federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Condition: There were two instances in which documentation was not available to support amounts included within reports submitted. These instances affected the Federal Financial Report and the UDS report. Questioned costs: None. Context: Documentation was not available to support the amount reported on line E, Federal share of expenditures, of the ARPA Federal Financial Report. In addition, there was no documentation to support two key lines items of the UDS report, Table 9E, Lines 1g and 1q, Column A. Cause: Management turnover Effect: Inaccurate reports could be file if there is no underlying documentation to support the amounts reported. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-07. Recommendation: We recommend that the Organization maintain supporting documentation for all reports required to be filed to the federal agency. Views of responsible officials: There is no disagreement with the audit finding.
2022-006 – Reporting Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: § 200.329 indicates that the non-federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Condition: There were two instances in which documentation was not available to support amounts included within reports submitted. These instances affected the Federal Financial Report and the UDS report. Questioned costs: None. Context: Documentation was not available to support the amount reported on line E, Federal share of expenditures, of the ARPA Federal Financial Report. In addition, there was no documentation to support two key lines items of the UDS report, Table 9E, Lines 1g and 1q, Column A. Cause: Management turnover Effect: Inaccurate reports could be file if there is no underlying documentation to support the amounts reported. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-07. Recommendation: We recommend that the Organization maintain supporting documentation for all reports required to be filed to the federal agency. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: United States Department of Commerce Federal Program Name: Office for Coastal Management Assistance Listing Number: 11.473 Federal Award Identification Year: 2020 Pass-Through Agency: National Fish and Wildlife Grant Agreement Award Period: 9/1/20-08/31/23 Type of Finding: Other Matters - Significant Deficiency in Internal Control Criteria: 2 CFR 200.328 - Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB approved, governmentwide data elements available from the OMB designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. 2 CFR 200.329(c)(1) -Requirements state that the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or passthrough entity to best inform improvements in program outcomes and productivity. Condition: For one of the two reports selected for testing, CFSC did not submit the reports to the National Fish and Wildlife Foundation by the required date. Context: A nonstatistical sample of 2 out of 4 required reports were selected for testing for the Office for Coastal Management program. The condition noted above was identified during our procedures over the CFSC’s reporting requirements. Effect: CFSC did not submit required reports in a timely manner, increasing the risk of noncompliance. Cause: CFSC’s procedures did not consistently ensure that the required reports were submitted on a timely basis. Repeat Finding: The finding is a repeat finding. Recommendation: We recommend that management modify and strengthen its current policies and procedures to ensure that all required reports are submitted on a timely basis to the appropriate Federal Agency or Pass-Through Entity. Management’s Views: See separate corrective action plan.
2 CFR § 1000.10 gives regulatory effect to Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200 for the Department of Treasury. 2 CFR 200.329(c)(1) states that non-Federal entities must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Reports submitted quarterly must be due no later than 30 calendar days after the reporting period. 31 CFR 35.4(c) requires recipients, in part, during the period of performance, to provide the Secretary of the U.S. Department of Treasury periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. The U.S. Department of Treasury provided supplementary information on reporting requirements in its interim final rule for State and Local Fiscal Recovery Funds for 31 CFR Part 35 and provided further guidance in its Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guide. The County was required to submit the initial Project and Expenditure Report for the period from March 3, 2021 to March 31, 2022 to the U.S Department of Treasury by April 30, 2022. Per review of the initial filed Project and Expenditure Report the report was filed on May 10, 2022, which was after the required due date. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, 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). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, 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). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, 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). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, 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). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, 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). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, 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). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL Number Award Number Award Period Grant Name 15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services U.S. Department of Transportation AL Number Award Number Award Period Grant Name 20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster Criteria: Per 2 CFR § 200.303 Internal controls, 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). Reporting requirements are contained in the following: Financial reporting, 2 CFR section 200.328. Monitoring and reporting program performance, 2 CFR section 200.329. Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation. Condition/Context: 15.029 – Judicial Services Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports. 20.205 – Highway Planning and Construction Cluster Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2021-006. Recommendation: Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS04200-17-01 and H80CS04200-18.01 Award Periods: May 1, 2021 ? April 30, 2022; May 1, 2022 ? April 30, 2023 Type of Finding: Compliance and Significant deficiency in internal control over compliance Criteria: 2 CFR 200.329(b) requires the Federal awarding agency to use OMB approved common information collections, when providing financial and performance reporting information. As appropriate and in accordance with above mentioned information collections, the Federal awarding agency must require the recipient to relate financial data and accomplishments to performance goals and objectives of the Federal award. In addition, OMB Compliance Supplement Part IV for assistance listing number 93.224/93.527 has designated key line items within the Uniform Data System (UDS) report. 2 CFR 200.334 indicates that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency. Condition: The organization was not able to provide sufficient supporting documentation for amounts reported in Table 8A of the UDS report for calendar year 2021. Questioned Costs: None. Context: Two (2) of Seven (7) key line items tested. Cause: During the time in which the UDS report was being prepared, the organization experienced a flood at its corporate headquarters resulting in disruption of operations. As the preparation of the UDS report occurred during the aforementioned disruption, the applicable supporting documentation for two of the key line items within the UDS report, were not saved and/or maintained in electronic format in order to allow for ease of recovery.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS04200-17-01 and H80CS04200-18.01 Award Periods: May 1, 2021 ? April 30, 2022; May 1, 2022 ? April 30, 2023 Type of Finding: Compliance and Significant deficiency in internal control over compliance Criteria: 2 CFR 200.329(b) requires the Federal awarding agency to use OMB approved common information collections, when providing financial and performance reporting information. As appropriate and in accordance with above mentioned information collections, the Federal awarding agency must require the recipient to relate financial data and accomplishments to performance goals and objectives of the Federal award. In addition, OMB Compliance Supplement Part IV for assistance listing number 93.224/93.527 has designated key line items within the Uniform Data System (UDS) report. 2 CFR 200.334 indicates that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency. Condition: The organization was not able to provide sufficient supporting documentation for amounts reported in Table 8A of the UDS report for calendar year 2021. Questioned Costs: None. Context: Two (2) of Seven (7) key line items tested. Cause: During the time in which the UDS report was being prepared, the organization experienced a flood at its corporate headquarters resulting in disruption of operations. As the preparation of the UDS report occurred during the aforementioned disruption, the applicable supporting documentation for two of the key line items within the UDS report, were not saved and/or maintained in electronic format in order to allow for ease of recovery.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS04200-17-01 and H80CS04200-18.01 Award Periods: May 1, 2021 ? April 30, 2022; May 1, 2022 ? April 30, 2023 Type of Finding: Compliance and Significant deficiency in internal control over compliance Criteria: 2 CFR 200.329(b) requires the Federal awarding agency to use OMB approved common information collections, when providing financial and performance reporting information. As appropriate and in accordance with above mentioned information collections, the Federal awarding agency must require the recipient to relate financial data and accomplishments to performance goals and objectives of the Federal award. In addition, OMB Compliance Supplement Part IV for assistance listing number 93.224/93.527 has designated key line items within the Uniform Data System (UDS) report. 2 CFR 200.334 indicates that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency. Condition: The organization was not able to provide sufficient supporting documentation for amounts reported in Table 8A of the UDS report for calendar year 2021. Questioned Costs: None. Context: Two (2) of Seven (7) key line items tested. Cause: During the time in which the UDS report was being prepared, the organization experienced a flood at its corporate headquarters resulting in disruption of operations. As the preparation of the UDS report occurred during the aforementioned disruption, the applicable supporting documentation for two of the key line items within the UDS report, were not saved and/or maintained in electronic format in order to allow for ease of recovery.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS04200-17-01 and H80CS04200-18.01 Award Periods: May 1, 2021 ? April 30, 2022; May 1, 2022 ? April 30, 2023 Type of Finding: Compliance and Significant deficiency in internal control over compliance Criteria: 2 CFR 200.329(b) requires the Federal awarding agency to use OMB approved common information collections, when providing financial and performance reporting information. As appropriate and in accordance with above mentioned information collections, the Federal awarding agency must require the recipient to relate financial data and accomplishments to performance goals and objectives of the Federal award. In addition, OMB Compliance Supplement Part IV for assistance listing number 93.224/93.527 has designated key line items within the Uniform Data System (UDS) report. 2 CFR 200.334 indicates that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency. Condition: The organization was not able to provide sufficient supporting documentation for amounts reported in Table 8A of the UDS report for calendar year 2021. Questioned Costs: None. Context: Two (2) of Seven (7) key line items tested. Cause: During the time in which the UDS report was being prepared, the organization experienced a flood at its corporate headquarters resulting in disruption of operations. As the preparation of the UDS report occurred during the aforementioned disruption, the applicable supporting documentation for two of the key line items within the UDS report, were not saved and/or maintained in electronic format in order to allow for ease of recovery.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS04200-17-01 and H80CS04200-18.01 Award Periods: May 1, 2021 ? April 30, 2022; May 1, 2022 ? April 30, 2023 Type of Finding: Compliance and Significant deficiency in internal control over compliance Criteria: 2 CFR 200.329(b) requires the Federal awarding agency to use OMB approved common information collections, when providing financial and performance reporting information. As appropriate and in accordance with above mentioned information collections, the Federal awarding agency must require the recipient to relate financial data and accomplishments to performance goals and objectives of the Federal award. In addition, OMB Compliance Supplement Part IV for assistance listing number 93.224/93.527 has designated key line items within the Uniform Data System (UDS) report. 2 CFR 200.334 indicates that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency. Condition: The organization was not able to provide sufficient supporting documentation for amounts reported in Table 8A of the UDS report for calendar year 2021. Questioned Costs: None. Context: Two (2) of Seven (7) key line items tested. Cause: During the time in which the UDS report was being prepared, the organization experienced a flood at its corporate headquarters resulting in disruption of operations. As the preparation of the UDS report occurred during the aforementioned disruption, the applicable supporting documentation for two of the key line items within the UDS report, were not saved and/or maintained in electronic format in order to allow for ease of recovery.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS04200-17-01 and H80CS04200-18.01 Award Periods: May 1, 2021 ? April 30, 2022; May 1, 2022 ? April 30, 2023 Type of Finding: Compliance and Significant deficiency in internal control over compliance Criteria: 2 CFR 200.329(b) requires the Federal awarding agency to use OMB approved common information collections, when providing financial and performance reporting information. As appropriate and in accordance with above mentioned information collections, the Federal awarding agency must require the recipient to relate financial data and accomplishments to performance goals and objectives of the Federal award. In addition, OMB Compliance Supplement Part IV for assistance listing number 93.224/93.527 has designated key line items within the Uniform Data System (UDS) report. 2 CFR 200.334 indicates that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency. Condition: The organization was not able to provide sufficient supporting documentation for amounts reported in Table 8A of the UDS report for calendar year 2021. Questioned Costs: None. Context: Two (2) of Seven (7) key line items tested. Cause: During the time in which the UDS report was being prepared, the organization experienced a flood at its corporate headquarters resulting in disruption of operations. As the preparation of the UDS report occurred during the aforementioned disruption, the applicable supporting documentation for two of the key line items within the UDS report, were not saved and/or maintained in electronic format in order to allow for ease of recovery.
Finding Number: 2022-008 Prior Year Finding Number: 2021-010 Compliance Requirement: Reporting Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ALN #: 84.425E Award #: P425E201913 - 20B Award Year: 04/24/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Institutional Aid Portion ALN: 84.425F Award #: P425F202580 - 20B Award Year: 05/07/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Historically Black Colleges and Universities (HBCUs) ALN: 84.425J Award #: P425J200098 - 20C Award Year: 05/01/2020 ? 06/30/2023 Government Department/Agency: University of the District of Columbia Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, Education Department exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition ? During our testing of the quarterly public reporting requirements for HEERF Student Aid Portion and HEERF Institutional Portion, we noted the following: ? For three (3) out of six (6) reports, University of the District of Columbia (UDC) was not able to provide evidence of the timely posting of the quarterly public reports to the UDC website because the webmaster?s web posting audit log, which expires after 60 days, had not been retained by UDC. ? For three (3) out of six (6) reports, UDC was not able to provide evidence that the quarterly public reports were reviewed prior to posting to the UDC website because the evidence had not been retained by UDC. UDC implemented its corrective action plan on June 30, 2022, and the exceptions identified above relate to reporting transactions made prior to the above-mentioned implementation date. We also examined one report made post the above-mentioned implementation date and we noted that UDC had kept all evidence of review of the report and the evidence of the report being published in the UDC website. Questioned Costs ? None. Context ? This is a condition identified per review of UDC?s compliance with specified reporting requirements related to the program using a statistically valid sample. Effect ? Without adequate controls in place to ensure that reports are posted timely and proof that the reports were reviewed leads to noncompliance of the reporting requirements under the program. Cause ? UDC does not have adequate controls in place to ensure that documents are maintained related to the review and the timely posting of reports to the UDC website. Recommendation ? We recommend for UDC to continue to maintain documentation of the timely submission of reports and proof of review of reports as required to ensure compliance with reporting requirements. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? UDC OCFO agrees with the conditions and recommendations of this finding. As noted in the condition above, UDC implemented corrective action to remediate the conditions and recommendations reported in the prior year when findings were issued. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-008 Prior Year Finding Number: 2021-010 Compliance Requirement: Reporting Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ALN #: 84.425E Award #: P425E201913 - 20B Award Year: 04/24/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Institutional Aid Portion ALN: 84.425F Award #: P425F202580 - 20B Award Year: 05/07/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Historically Black Colleges and Universities (HBCUs) ALN: 84.425J Award #: P425J200098 - 20C Award Year: 05/01/2020 ? 06/30/2023 Government Department/Agency: University of the District of Columbia Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, Education Department exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition ? During our testing of the quarterly public reporting requirements for HEERF Student Aid Portion and HEERF Institutional Portion, we noted the following: ? For three (3) out of six (6) reports, University of the District of Columbia (UDC) was not able to provide evidence of the timely posting of the quarterly public reports to the UDC website because the webmaster?s web posting audit log, which expires after 60 days, had not been retained by UDC. ? For three (3) out of six (6) reports, UDC was not able to provide evidence that the quarterly public reports were reviewed prior to posting to the UDC website because the evidence had not been retained by UDC. UDC implemented its corrective action plan on June 30, 2022, and the exceptions identified above relate to reporting transactions made prior to the above-mentioned implementation date. We also examined one report made post the above-mentioned implementation date and we noted that UDC had kept all evidence of review of the report and the evidence of the report being published in the UDC website. Questioned Costs ? None. Context ? This is a condition identified per review of UDC?s compliance with specified reporting requirements related to the program using a statistically valid sample. Effect ? Without adequate controls in place to ensure that reports are posted timely and proof that the reports were reviewed leads to noncompliance of the reporting requirements under the program. Cause ? UDC does not have adequate controls in place to ensure that documents are maintained related to the review and the timely posting of reports to the UDC website. Recommendation ? We recommend for UDC to continue to maintain documentation of the timely submission of reports and proof of review of reports as required to ensure compliance with reporting requirements. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? UDC OCFO agrees with the conditions and recommendations of this finding. As noted in the condition above, UDC implemented corrective action to remediate the conditions and recommendations reported in the prior year when findings were issued. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-008 Prior Year Finding Number: 2021-010 Compliance Requirement: Reporting Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ALN #: 84.425E Award #: P425E201913 - 20B Award Year: 04/24/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Institutional Aid Portion ALN: 84.425F Award #: P425F202580 - 20B Award Year: 05/07/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Historically Black Colleges and Universities (HBCUs) ALN: 84.425J Award #: P425J200098 - 20C Award Year: 05/01/2020 ? 06/30/2023 Government Department/Agency: University of the District of Columbia Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, Education Department exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition ? During our testing of the quarterly public reporting requirements for HEERF Student Aid Portion and HEERF Institutional Portion, we noted the following: ? For three (3) out of six (6) reports, University of the District of Columbia (UDC) was not able to provide evidence of the timely posting of the quarterly public reports to the UDC website because the webmaster?s web posting audit log, which expires after 60 days, had not been retained by UDC. ? For three (3) out of six (6) reports, UDC was not able to provide evidence that the quarterly public reports were reviewed prior to posting to the UDC website because the evidence had not been retained by UDC. UDC implemented its corrective action plan on June 30, 2022, and the exceptions identified above relate to reporting transactions made prior to the above-mentioned implementation date. We also examined one report made post the above-mentioned implementation date and we noted that UDC had kept all evidence of review of the report and the evidence of the report being published in the UDC website. Questioned Costs ? None. Context ? This is a condition identified per review of UDC?s compliance with specified reporting requirements related to the program using a statistically valid sample. Effect ? Without adequate controls in place to ensure that reports are posted timely and proof that the reports were reviewed leads to noncompliance of the reporting requirements under the program. Cause ? UDC does not have adequate controls in place to ensure that documents are maintained related to the review and the timely posting of reports to the UDC website. Recommendation ? We recommend for UDC to continue to maintain documentation of the timely submission of reports and proof of review of reports as required to ensure compliance with reporting requirements. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? UDC OCFO agrees with the conditions and recommendations of this finding. As noted in the condition above, UDC implemented corrective action to remediate the conditions and recommendations reported in the prior year when findings were issued. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Federal Grantor: US Department of Homeland Security Federal Emergency Management Agency (FEMA) Assistance Listing No.: 97.036 - Disaster Grants ? Public Assistance (Presidentially Declared Disasters) Criteria or specific requirement (including statutory, regulatory or other citation): The Uniform Guidance 2 CFR section 200.303 states, ?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).? The Uniform Guidance 2 CFR section 200.329 states, ?(b) The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. As appropriate and in accordance with above mentioned information collections, the Federal awarding agency must require the recipient to relate financial data and accomplishments to performance goals and objectives of the Federal award. Also, in accordance with the above mentioned common information collections, and when required by the terms and conditions of the Federal award, recipients must provide cost information to demonstrate cost effective practices (e.g. through unit cost data). In some instances (e.g., discretionary research awards), this will be limited to the requirement to submit technical performance reports (to be evaluated in accordance with Federal awarding agency policy).? Reporting requirements must be clearly articulated such that, where appropriate, performance during the execution of the Federal award has a standard against which non-Federal entity performance can be measured. Condition: Baptist Health Care Corporation and Subsidiaries (the Company) received funding under program 97.036 - Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (Program) during the fiscal year ended September 30, 2022. Under the conditions of the grant, the Company is required to submit quarterly progress reports on all open large projects 30 days after the end of each calendar quarter as well as an annual report SF-425, Federal Financial Report. Based on discussions with management, we understand that the Company?s report submissions were outsourced to a contracted third party on the Company?s behalf. However, management did not establish internal controls over compliance to validate the reporting was complete and accurate prior to submission. As such, we consider the lack of design of controls to validate completeness and accuracy of reporting for this program to represent a material weakness in internal control over compliance. Cause The Company?s internal controls in place over the review of the completeness and accuracy of reporting under the Program were not sufficient to review and supervise the work performed by third party contractors. Effect or potential effect The lack of management review of the reports to be submitted by the contracted third party regarding this Program could have resulted in inaccurate reporting to the granting agency. Questioned costs None. Context: See above. Identification as a repeat finding, if applicable Not applicable. Recommendation The Company should implement controls to review the completeness and accuracy of required reports to be submitted by the third-party prior to the submission of quarterly reporting. In addition, the Company should communicate to the third party that the reporting should be explicitly authorized by an appropriate individual in the Company?s management prior to submission. Views of responsible officials: The Company agrees with the comment and will prospectively correct the finding regarding the major program through reviewing the completeness and accuracy of reporting prior to submission. See separate Corrective Action Plan.
Finding Number: 2022-008 Prior Year Finding Number: 2021-010 Compliance Requirement: Reporting Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ALN #: 84.425E Award #: P425E201913 - 20B Award Year: 04/24/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Institutional Aid Portion ALN: 84.425F Award #: P425F202580 - 20B Award Year: 05/07/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Historically Black Colleges and Universities (HBCUs) ALN: 84.425J Award #: P425J200098 - 20C Award Year: 05/01/2020 ? 06/30/2023 Government Department/Agency: University of the District of Columbia Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, Education Department exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition ? During our testing of the quarterly public reporting requirements for HEERF Student Aid Portion and HEERF Institutional Portion, we noted the following: ? For three (3) out of six (6) reports, University of the District of Columbia (UDC) was not able to provide evidence of the timely posting of the quarterly public reports to the UDC website because the webmaster?s web posting audit log, which expires after 60 days, had not been retained by UDC. ? For three (3) out of six (6) reports, UDC was not able to provide evidence that the quarterly public reports were reviewed prior to posting to the UDC website because the evidence had not been retained by UDC. UDC implemented its corrective action plan on June 30, 2022, and the exceptions identified above relate to reporting transactions made prior to the above-mentioned implementation date. We also examined one report made post the above-mentioned implementation date and we noted that UDC had kept all evidence of review of the report and the evidence of the report being published in the UDC website. Questioned Costs ? None. Context ? This is a condition identified per review of UDC?s compliance with specified reporting requirements related to the program using a statistically valid sample. Effect ? Without adequate controls in place to ensure that reports are posted timely and proof that the reports were reviewed leads to noncompliance of the reporting requirements under the program. Cause ? UDC does not have adequate controls in place to ensure that documents are maintained related to the review and the timely posting of reports to the UDC website. Recommendation ? We recommend for UDC to continue to maintain documentation of the timely submission of reports and proof of review of reports as required to ensure compliance with reporting requirements. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? UDC OCFO agrees with the conditions and recommendations of this finding. As noted in the condition above, UDC implemented corrective action to remediate the conditions and recommendations reported in the prior year when findings were issued. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-008 Prior Year Finding Number: 2021-010 Compliance Requirement: Reporting Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ALN #: 84.425E Award #: P425E201913 - 20B Award Year: 04/24/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Institutional Aid Portion ALN: 84.425F Award #: P425F202580 - 20B Award Year: 05/07/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Historically Black Colleges and Universities (HBCUs) ALN: 84.425J Award #: P425J200098 - 20C Award Year: 05/01/2020 ? 06/30/2023 Government Department/Agency: University of the District of Columbia Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, Education Department exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition ? During our testing of the quarterly public reporting requirements for HEERF Student Aid Portion and HEERF Institutional Portion, we noted the following: ? For three (3) out of six (6) reports, University of the District of Columbia (UDC) was not able to provide evidence of the timely posting of the quarterly public reports to the UDC website because the webmaster?s web posting audit log, which expires after 60 days, had not been retained by UDC. ? For three (3) out of six (6) reports, UDC was not able to provide evidence that the quarterly public reports were reviewed prior to posting to the UDC website because the evidence had not been retained by UDC. UDC implemented its corrective action plan on June 30, 2022, and the exceptions identified above relate to reporting transactions made prior to the above-mentioned implementation date. We also examined one report made post the above-mentioned implementation date and we noted that UDC had kept all evidence of review of the report and the evidence of the report being published in the UDC website. Questioned Costs ? None. Context ? This is a condition identified per review of UDC?s compliance with specified reporting requirements related to the program using a statistically valid sample. Effect ? Without adequate controls in place to ensure that reports are posted timely and proof that the reports were reviewed leads to noncompliance of the reporting requirements under the program. Cause ? UDC does not have adequate controls in place to ensure that documents are maintained related to the review and the timely posting of reports to the UDC website. Recommendation ? We recommend for UDC to continue to maintain documentation of the timely submission of reports and proof of review of reports as required to ensure compliance with reporting requirements. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? UDC OCFO agrees with the conditions and recommendations of this finding. As noted in the condition above, UDC implemented corrective action to remediate the conditions and recommendations reported in the prior year when findings were issued. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-008 Prior Year Finding Number: 2021-010 Compliance Requirement: Reporting Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ALN #: 84.425E Award #: P425E201913 - 20B Award Year: 04/24/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Institutional Aid Portion ALN: 84.425F Award #: P425F202580 - 20B Award Year: 05/07/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Historically Black Colleges and Universities (HBCUs) ALN: 84.425J Award #: P425J200098 - 20C Award Year: 05/01/2020 ? 06/30/2023 Government Department/Agency: University of the District of Columbia Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, Education Department exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition ? During our testing of the quarterly public reporting requirements for HEERF Student Aid Portion and HEERF Institutional Portion, we noted the following: ? For three (3) out of six (6) reports, University of the District of Columbia (UDC) was not able to provide evidence of the timely posting of the quarterly public reports to the UDC website because the webmaster?s web posting audit log, which expires after 60 days, had not been retained by UDC. ? For three (3) out of six (6) reports, UDC was not able to provide evidence that the quarterly public reports were reviewed prior to posting to the UDC website because the evidence had not been retained by UDC. UDC implemented its corrective action plan on June 30, 2022, and the exceptions identified above relate to reporting transactions made prior to the above-mentioned implementation date. We also examined one report made post the above-mentioned implementation date and we noted that UDC had kept all evidence of review of the report and the evidence of the report being published in the UDC website. Questioned Costs ? None. Context ? This is a condition identified per review of UDC?s compliance with specified reporting requirements related to the program using a statistically valid sample. Effect ? Without adequate controls in place to ensure that reports are posted timely and proof that the reports were reviewed leads to noncompliance of the reporting requirements under the program. Cause ? UDC does not have adequate controls in place to ensure that documents are maintained related to the review and the timely posting of reports to the UDC website. Recommendation ? We recommend for UDC to continue to maintain documentation of the timely submission of reports and proof of review of reports as required to ensure compliance with reporting requirements. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? UDC OCFO agrees with the conditions and recommendations of this finding. As noted in the condition above, UDC implemented corrective action to remediate the conditions and recommendations reported in the prior year when findings were issued. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Federal Grantor: US Department of Homeland Security Federal Emergency Management Agency (FEMA) Assistance Listing No.: 97.036 - Disaster Grants ? Public Assistance (Presidentially Declared Disasters) Criteria or specific requirement (including statutory, regulatory or other citation): The Uniform Guidance 2 CFR section 200.303 states, ?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).? The Uniform Guidance 2 CFR section 200.329 states, ?(b) The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. As appropriate and in accordance with above mentioned information collections, the Federal awarding agency must require the recipient to relate financial data and accomplishments to performance goals and objectives of the Federal award. Also, in accordance with the above mentioned common information collections, and when required by the terms and conditions of the Federal award, recipients must provide cost information to demonstrate cost effective practices (e.g. through unit cost data). In some instances (e.g., discretionary research awards), this will be limited to the requirement to submit technical performance reports (to be evaluated in accordance with Federal awarding agency policy).? Reporting requirements must be clearly articulated such that, where appropriate, performance during the execution of the Federal award has a standard against which non-Federal entity performance can be measured. Condition: Baptist Health Care Corporation and Subsidiaries (the Company) received funding under program 97.036 - Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (Program) during the fiscal year ended September 30, 2022. Under the conditions of the grant, the Company is required to submit quarterly progress reports on all open large projects 30 days after the end of each calendar quarter as well as an annual report SF-425, Federal Financial Report. Based on discussions with management, we understand that the Company?s report submissions were outsourced to a contracted third party on the Company?s behalf. However, management did not establish internal controls over compliance to validate the reporting was complete and accurate prior to submission. As such, we consider the lack of design of controls to validate completeness and accuracy of reporting for this program to represent a material weakness in internal control over compliance. Cause The Company?s internal controls in place over the review of the completeness and accuracy of reporting under the Program were not sufficient to review and supervise the work performed by third party contractors. Effect or potential effect The lack of management review of the reports to be submitted by the contracted third party regarding this Program could have resulted in inaccurate reporting to the granting agency. Questioned costs None. Context: See above. Identification as a repeat finding, if applicable Not applicable. Recommendation The Company should implement controls to review the completeness and accuracy of required reports to be submitted by the third-party prior to the submission of quarterly reporting. In addition, the Company should communicate to the third party that the reporting should be explicitly authorized by an appropriate individual in the Company?s management prior to submission. Views of responsible officials: The Company agrees with the comment and will prospectively correct the finding regarding the major program through reviewing the completeness and accuracy of reporting prior to submission. See separate Corrective Action Plan.
REPORTING, I DID NOT NOTE ANY ANNUAL REPORTS FILED FOR THE ARP GRANT. PER 2 CFR, SECTION 200.328 AND 200.329, THE NVT MUST COMPLY WITH ANY FINANCIAL AND PROGRAMMATIC REPORTING REQUIREMENTS. NO QUESTIONED COSTS. MANAGEMENT DID NOT HAVE CONTROLS IN PLACE TO ENSURE THAT ALL GRANT REPORTS WERE FILED TIMELY. I WAS NOT ABLE TO REVIEW THE ANNUAL REQUIRED REPORT FOR THE ARP GRANT. THE NVT IS DELINQUENT IN ITS REPORTING FOR THIS GRANT. MANAGEMENT NEEDS TO ENSURE THAT ALL GRANT REPORTS ARE DONE AND SUBMITTED TIMELY AND RETAINED WITHIN THE GRANT FILES OF THE NVT. THIS FINDING WAS NOTED AS FINDING 2021-002.
OTHER, THE NVT DID NOT SUBMIT THE REPORTING PACKAGE TIMELY IN ACCORDANCE WITH THE UNIFORM GUIDANCE REQUIREMENT OF SUBMITTING THE AUDIT WITHIN THE EARLIER OF 30 DAYS AFTER RECEIPT OF THE AUDIT REPORT, OR NINE MONTHS AFTER THE END OF THE AUDIT PERIOD. PER 2 CFR, SECTION 200.328 AND 200.329, THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATTIC REPORTING REQUIREMENTS. PER SECTION 200.501, THE NVT MUST HAEV AN AUDIT PERFORMED AND SUBMITTED WITHIN 9 MONTHS OF YEAR END. NO QUESTIONED COSTS. MANAGEMENT DID NOT ENSURE THAT THE AUDITS WERE PERFORMED TIMELY. LATE REPORTING COULD JEOPARDIZE GRANT FUNDING. I RECOMMEND THAT THE COUNCIL ENSURE TIMELY AUDITS FOR FUTURE AUDITS. THIS FINDING WAS NOTED AS FINDING 2020-003 AND 2021-003.
2022-027 Reporting ? ACF-196R and ACF-204 Reports ? Inaccurate Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families (TANF) ALN: 93.558 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2001TXTANF, 2101TXTANF and 2201TXTANF October 1, 2019 ? September 30, 2022, October 1, 2020 ? September 30, 2023, October 1, 2021 ? September 30, 2024, Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), a 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 Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Pursuant to 45 CFR 265.3(a)(1) each State must collect on a monthly basis, and file on a quarterly basis, the data specified in the TANF Data Report and the TANF Financial Report (or, as applicable, the Territorial Financial Report). More specifically, Form ACF-196R is used by States administering the Temporary Assistance for Needy Families (TANF) program to report quarterly expenditure data and to request quarterly grant funds. Per 2 CFR 200.329(b) Reporting program performance, the Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. As appropriate and in accordance with above mentioned information collections, the Federal awarding agency must require the recipient to relate financial data and accomplishments to performance goals and objectives of the Federal award. Condition: Audit procedures over financial reports included testing of three quarterly ACF-196R reports. All three reports had expenditures incorrectly reported as follows: ? Grant Year 2020 ACF-196R for the quarter-ended 9/30/2021 Line 9b, Education and Training was understated by $987,108 Line 9c, Additional Work Activities was overstated by $5,079,845 Line 17, Services for Children and Youth was understated by $4,092,737 ? Grant Year 2021 ACF-196R for the quarter-ended 3/31/2022 Line 9b, Education and Training was understated by $716,670 Line 9c, Additional Work Activities was overstated by $4,555,850 Line 17, Services for Children and Youth was understated by $3,839,180 ? Grant Year 2022 ACF-196R for the quarter-ended 3/31/2022 Line 9b, Education and Training was overstated by $137,683 Line 9c, Additional Work Activities was overstated by $950,355 Line 17, Services for Children and Youth was understated by $1,088,038 Audit procedures over special reports included testing of the ACF-204, Annual Report including the Annual Report on State Maintenance-of-Effort Programs (OMB No. 0970-0248) for federal fiscal year 2021, which requires TWC to file an annual report containing information on the TANF program and the state?s MOE programs for that year, including strategies to implement the Family Violence Option, state diversion programs, and other program characteristics. Key line items include line 8 for the total number of families served under the program with MOE funds. We noted that this line was overstated by 9,784 families. Questioned costs: None Context: See ?Condition.? Cause: The ACF-196R and ACF-204 are populated from data retrieved through preset queries from CAPP and TWIST, respectively. Queries were written incorrectly and thus did not output accurate information. Effect: Failure to report accurate data on the ACF-196R could compromise the Office of Family Assistance (OFA) and the ACF?s ability to monitor TANF expenditures and compliance with statutory requirements. These data are also needed to estimate outlays and to prepare reports and budget submissions for Congress. Additionally, failure to report accurate data on the ACF-204 inhibits ACF?s ability to monitor the nature of State and Territory expenditures used to meet States and Territories MOE requirements. Repeat Finding: No Recommendation: TWC should perform a review of all queries used to retrieve data when populating the ACF 196R and ACF-204 reports to ensure accurate data is being outputted in accordance with the requirements of the respective reports. Views of responsible officials: The Texas Workforce Commission acknowledges and agrees with the findings. Through analysis of report criteria, the Texas Workforce Commission has developed and implemented corrective action to address this finding.
2022-027 Reporting ? ACF-196R and ACF-204 Reports ? Inaccurate Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families (TANF) ALN: 93.558 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2001TXTANF, 2101TXTANF and 2201TXTANF October 1, 2019 ? September 30, 2022, October 1, 2020 ? September 30, 2023, October 1, 2021 ? September 30, 2024, Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), a 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 Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Pursuant to 45 CFR 265.3(a)(1) each State must collect on a monthly basis, and file on a quarterly basis, the data specified in the TANF Data Report and the TANF Financial Report (or, as applicable, the Territorial Financial Report). More specifically, Form ACF-196R is used by States administering the Temporary Assistance for Needy Families (TANF) program to report quarterly expenditure data and to request quarterly grant funds. Per 2 CFR 200.329(b) Reporting program performance, the Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. As appropriate and in accordance with above mentioned information collections, the Federal awarding agency must require the recipient to relate financial data and accomplishments to performance goals and objectives of the Federal award. Condition: Audit procedures over financial reports included testing of three quarterly ACF-196R reports. All three reports had expenditures incorrectly reported as follows: ? Grant Year 2020 ACF-196R for the quarter-ended 9/30/2021 Line 9b, Education and Training was understated by $987,108 Line 9c, Additional Work Activities was overstated by $5,079,845 Line 17, Services for Children and Youth was understated by $4,092,737 ? Grant Year 2021 ACF-196R for the quarter-ended 3/31/2022 Line 9b, Education and Training was understated by $716,670 Line 9c, Additional Work Activities was overstated by $4,555,850 Line 17, Services for Children and Youth was understated by $3,839,180 ? Grant Year 2022 ACF-196R for the quarter-ended 3/31/2022 Line 9b, Education and Training was overstated by $137,683 Line 9c, Additional Work Activities was overstated by $950,355 Line 17, Services for Children and Youth was understated by $1,088,038 Audit procedures over special reports included testing of the ACF-204, Annual Report including the Annual Report on State Maintenance-of-Effort Programs (OMB No. 0970-0248) for federal fiscal year 2021, which requires TWC to file an annual report containing information on the TANF program and the state?s MOE programs for that year, including strategies to implement the Family Violence Option, state diversion programs, and other program characteristics. Key line items include line 8 for the total number of families served under the program with MOE funds. We noted that this line was overstated by 9,784 families. Questioned costs: None Context: See ?Condition.? Cause: The ACF-196R and ACF-204 are populated from data retrieved through preset queries from CAPP and TWIST, respectively. Queries were written incorrectly and thus did not output accurate information. Effect: Failure to report accurate data on the ACF-196R could compromise the Office of Family Assistance (OFA) and the ACF?s ability to monitor TANF expenditures and compliance with statutory requirements. These data are also needed to estimate outlays and to prepare reports and budget submissions for Congress. Additionally, failure to report accurate data on the ACF-204 inhibits ACF?s ability to monitor the nature of State and Territory expenditures used to meet States and Territories MOE requirements. Repeat Finding: No Recommendation: TWC should perform a review of all queries used to retrieve data when populating the ACF 196R and ACF-204 reports to ensure accurate data is being outputted in accordance with the requirements of the respective reports. Views of responsible officials: The Texas Workforce Commission acknowledges and agrees with the findings. Through analysis of report criteria, the Texas Workforce Commission has developed and implemented corrective action to address this finding.
Criteria: 2 CFR ?200.329 states the recipient is required to relate financial data and accomplishments to performance goals and objectives of the federal award. Condition: During audit procedures performed, we noted the Chamber did not meet the reporting compliance requirement per review of the contract agreement as one of the three required reports had been filed, and the one report filed was submitted late. Questioned Costs: None Context: Reports must be submitted to the awarding agency 45 days after the end of the quarter. There are three quarters in the contract period that fall within the fiscal year. Cause: The Chamber was unaware of the additional quarterly reporting requirements as this is the first single audit the Chamber has been through in addition to the speed in which the funds were spent due to COVID-19 and the emergency it created for businesses in the area. Effect: Failure of the Chamber to comply with the audit requirements may constitute a violation of the agreement and may result in the withholding of future payments. Recommendation: We recommend that the Chamber ensure all required reports are filed in a timely manner. Views of responsible officials: There is no disagreement with the audit finding.
2022-002 ? Internal Control over Compliance and Compliance with Reporting (Preparation of Schedule of Expenditures of Federal Awards) Information on the Federal Program: U.S. Small Business Administration Assistance Listing Number: 59.008 Assistance Listing Name: Economic Injury Disaster Loan Criteria ? The Code of Federal Regulation (CFR) Section ?200.510(b) states in part: ?The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section ?200.502 Basis for determining Federal awards expended.? The schedule must provide total Federal awards expended for each individual Federal program. In accordance with ?200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?200.328 Financial Reporting and ?200.329 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition ? During the year ended August 31, 2022, the Center received additional EIDL funds. Prior to the COVID-19 pandemic, the Center did not receive and spend federal dollars in excess of the limit that required a single audit to be performed. Due to the lack of expertise surrounding the preparation of the SEFA and the non-recurring nature of the COVID-19 pandemic relief funding provided by the federal government, the Center was uncertain of some of the specifics on the SEFA statement. Cause ? The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to new funding received in the current year. Effect ? Management was unaware that the EIDL was a federal award requiring a single audit prior to discussion with the auditors. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the Center?s major program and our overall testing of the accuracy of the SEFA. The nature of this findings is detailed in the condition section above. Repeat Finding: This is not a repeat finding. Recommendation ? We recommend management attend Federal award trainings and information to ensure the documented policies and procedures can be performed as described. This will ensure the Federal funds are reported accurately on the SEFA and that programs are reported under the correct assistance listing number. Views of Responsible Officials ? Beck Center for the Arts concurs with the finding and the recommendation. The Center will continue to review federal award guidance and requirements to ensure compliance with current and future federal awards. The Center?s corrective action plan is described in Managements Corrective Action Plan included at page 42 of this reporting package.
2022-027 Reporting ? ACF-196R and ACF-204 Reports ? Inaccurate Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families (TANF) ALN: 93.558 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2001TXTANF, 2101TXTANF and 2201TXTANF October 1, 2019 ? September 30, 2022, October 1, 2020 ? September 30, 2023, October 1, 2021 ? September 30, 2024, Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), a 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 Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Pursuant to 45 CFR 265.3(a)(1) each State must collect on a monthly basis, and file on a quarterly basis, the data specified in the TANF Data Report and the TANF Financial Report (or, as applicable, the Territorial Financial Report). More specifically, Form ACF-196R is used by States administering the Temporary Assistance for Needy Families (TANF) program to report quarterly expenditure data and to request quarterly grant funds. Per 2 CFR 200.329(b) Reporting program performance, the Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. As appropriate and in accordance with above mentioned information collections, the Federal awarding agency must require the recipient to relate financial data and accomplishments to performance goals and objectives of the Federal award. Condition: Audit procedures over financial reports included testing of three quarterly ACF-196R reports. All three reports had expenditures incorrectly reported as follows: ? Grant Year 2020 ACF-196R for the quarter-ended 9/30/2021 Line 9b, Education and Training was understated by $987,108 Line 9c, Additional Work Activities was overstated by $5,079,845 Line 17, Services for Children and Youth was understated by $4,092,737 ? Grant Year 2021 ACF-196R for the quarter-ended 3/31/2022 Line 9b, Education and Training was understated by $716,670 Line 9c, Additional Work Activities was overstated by $4,555,850 Line 17, Services for Children and Youth was understated by $3,839,180 ? Grant Year 2022 ACF-196R for the quarter-ended 3/31/2022 Line 9b, Education and Training was overstated by $137,683 Line 9c, Additional Work Activities was overstated by $950,355 Line 17, Services for Children and Youth was understated by $1,088,038 Audit procedures over special reports included testing of the ACF-204, Annual Report including the Annual Report on State Maintenance-of-Effort Programs (OMB No. 0970-0248) for federal fiscal year 2021, which requires TWC to file an annual report containing information on the TANF program and the state?s MOE programs for that year, including strategies to implement the Family Violence Option, state diversion programs, and other program characteristics. Key line items include line 8 for the total number of families served under the program with MOE funds. We noted that this line was overstated by 9,784 families. Questioned costs: None Context: See ?Condition.? Cause: The ACF-196R and ACF-204 are populated from data retrieved through preset queries from CAPP and TWIST, respectively. Queries were written incorrectly and thus did not output accurate information. Effect: Failure to report accurate data on the ACF-196R could compromise the Office of Family Assistance (OFA) and the ACF?s ability to monitor TANF expenditures and compliance with statutory requirements. These data are also needed to estimate outlays and to prepare reports and budget submissions for Congress. Additionally, failure to report accurate data on the ACF-204 inhibits ACF?s ability to monitor the nature of State and Territory expenditures used to meet States and Territories MOE requirements. Repeat Finding: No Recommendation: TWC should perform a review of all queries used to retrieve data when populating the ACF 196R and ACF-204 reports to ensure accurate data is being outputted in accordance with the requirements of the respective reports. Views of responsible officials: The Texas Workforce Commission acknowledges and agrees with the findings. Through analysis of report criteria, the Texas Workforce Commission has developed and implemented corrective action to address this finding.
2022-027 Reporting ? ACF-196R and ACF-204 Reports ? Inaccurate Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families (TANF) ALN: 93.558 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2001TXTANF, 2101TXTANF and 2201TXTANF October 1, 2019 ? September 30, 2022, October 1, 2020 ? September 30, 2023, October 1, 2021 ? September 30, 2024, Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), a 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 Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Pursuant to 45 CFR 265.3(a)(1) each State must collect on a monthly basis, and file on a quarterly basis, the data specified in the TANF Data Report and the TANF Financial Report (or, as applicable, the Territorial Financial Report). More specifically, Form ACF-196R is used by States administering the Temporary Assistance for Needy Families (TANF) program to report quarterly expenditure data and to request quarterly grant funds. Per 2 CFR 200.329(b) Reporting program performance, the Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. As appropriate and in accordance with above mentioned information collections, the Federal awarding agency must require the recipient to relate financial data and accomplishments to performance goals and objectives of the Federal award. Condition: Audit procedures over financial reports included testing of three quarterly ACF-196R reports. All three reports had expenditures incorrectly reported as follows: ? Grant Year 2020 ACF-196R for the quarter-ended 9/30/2021 Line 9b, Education and Training was understated by $987,108 Line 9c, Additional Work Activities was overstated by $5,079,845 Line 17, Services for Children and Youth was understated by $4,092,737 ? Grant Year 2021 ACF-196R for the quarter-ended 3/31/2022 Line 9b, Education and Training was understated by $716,670 Line 9c, Additional Work Activities was overstated by $4,555,850 Line 17, Services for Children and Youth was understated by $3,839,180 ? Grant Year 2022 ACF-196R for the quarter-ended 3/31/2022 Line 9b, Education and Training was overstated by $137,683 Line 9c, Additional Work Activities was overstated by $950,355 Line 17, Services for Children and Youth was understated by $1,088,038 Audit procedures over special reports included testing of the ACF-204, Annual Report including the Annual Report on State Maintenance-of-Effort Programs (OMB No. 0970-0248) for federal fiscal year 2021, which requires TWC to file an annual report containing information on the TANF program and the state?s MOE programs for that year, including strategies to implement the Family Violence Option, state diversion programs, and other program characteristics. Key line items include line 8 for the total number of families served under the program with MOE funds. We noted that this line was overstated by 9,784 families. Questioned costs: None Context: See ?Condition.? Cause: The ACF-196R and ACF-204 are populated from data retrieved through preset queries from CAPP and TWIST, respectively. Queries were written incorrectly and thus did not output accurate information. Effect: Failure to report accurate data on the ACF-196R could compromise the Office of Family Assistance (OFA) and the ACF?s ability to monitor TANF expenditures and compliance with statutory requirements. These data are also needed to estimate outlays and to prepare reports and budget submissions for Congress. Additionally, failure to report accurate data on the ACF-204 inhibits ACF?s ability to monitor the nature of State and Territory expenditures used to meet States and Territories MOE requirements. Repeat Finding: No Recommendation: TWC should perform a review of all queries used to retrieve data when populating the ACF 196R and ACF-204 reports to ensure accurate data is being outputted in accordance with the requirements of the respective reports. Views of responsible officials: The Texas Workforce Commission acknowledges and agrees with the findings. Through analysis of report criteria, the Texas Workforce Commission has developed and implemented corrective action to address this finding.
Criteria: 2 CFR ?200.329 states the recipient is required to relate financial data and accomplishments to performance goals and objectives of the federal award. Condition: During audit procedures performed, we noted the Chamber did not meet the reporting compliance requirement per review of the contract agreement as one of the three required reports had been filed, and the one report filed was submitted late. Questioned Costs: None Context: Reports must be submitted to the awarding agency 45 days after the end of the quarter. There are three quarters in the contract period that fall within the fiscal year. Cause: The Chamber was unaware of the additional quarterly reporting requirements as this is the first single audit the Chamber has been through in addition to the speed in which the funds were spent due to COVID-19 and the emergency it created for businesses in the area. Effect: Failure of the Chamber to comply with the audit requirements may constitute a violation of the agreement and may result in the withholding of future payments. Recommendation: We recommend that the Chamber ensure all required reports are filed in a timely manner. Views of responsible officials: There is no disagreement with the audit finding.
2022-002 ? Internal Control over Compliance and Compliance with Reporting (Preparation of Schedule of Expenditures of Federal Awards) Information on the Federal Program: U.S. Small Business Administration Assistance Listing Number: 59.008 Assistance Listing Name: Economic Injury Disaster Loan Criteria ? The Code of Federal Regulation (CFR) Section ?200.510(b) states in part: ?The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section ?200.502 Basis for determining Federal awards expended.? The schedule must provide total Federal awards expended for each individual Federal program. In accordance with ?200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?200.328 Financial Reporting and ?200.329 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition ? During the year ended August 31, 2022, the Center received additional EIDL funds. Prior to the COVID-19 pandemic, the Center did not receive and spend federal dollars in excess of the limit that required a single audit to be performed. Due to the lack of expertise surrounding the preparation of the SEFA and the non-recurring nature of the COVID-19 pandemic relief funding provided by the federal government, the Center was uncertain of some of the specifics on the SEFA statement. Cause ? The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to new funding received in the current year. Effect ? Management was unaware that the EIDL was a federal award requiring a single audit prior to discussion with the auditors. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the Center?s major program and our overall testing of the accuracy of the SEFA. The nature of this findings is detailed in the condition section above. Repeat Finding: This is not a repeat finding. Recommendation ? We recommend management attend Federal award trainings and information to ensure the documented policies and procedures can be performed as described. This will ensure the Federal funds are reported accurately on the SEFA and that programs are reported under the correct assistance listing number. Views of Responsible Officials ? Beck Center for the Arts concurs with the finding and the recommendation. The Center will continue to review federal award guidance and requirements to ensure compliance with current and future federal awards. The Center?s corrective action plan is described in Managements Corrective Action Plan included at page 42 of this reporting package.
Assistance listing program: Education Stabilization Fund - Higher Education Emergency Relief Fund (HEERF) Assistance Listing Number: 84.425E / 84.425F Award identification number: P425F204999 / P425E205418 Award period: September 29, 2020 to June 30, 2023 and July 23, 2020 to May 23, 2022 Federal agency: U.S. Department of Education Pass-through entity: N/A Category: Internal Control / Compliance Finding Type: Material Weakness Compliance requirement: Reporting Condition and context For testing internal controls and compliance with reporting requirements applicable to the HEERF programs, we inquired the Institution about the internal controls and procedures for determining the criteria and methodology used in compiling and reporting the data to be included in the annual and quarterly special reports. We requested a copy of the annual report for the calendar year 2021 and the quarterly reports for the quarter ended on December 31, 2021 related to the institutional aid portion and the student aid portion. As part of our procedures, we tested the method of distribution of grants to ascertain consistency with the method that was actually employed by the Institution to distribute emergency financial aid grants to students. After our examination and tests performed, we noted the following: a) The methodology used to compile the information in the annual report was based on the funds drawdowns which were based on disbursements rather than the actual program expenditures for the Institutional aid funds in accordance with GAAP. b) After examination of the institutional aid portion expenditures amounts reported in the annual special report for the calendar year ended December 31, 2021 to the support provided by the Institution, we noted that the total of institutional annual expenditures was understated by $7,160. c) From the sample of enrollment statistical data selected for verification to the source documents and/or information we noted several differences and were unable to identify some of the information in the source documents in nineteen (19) out of a sample of thirty (30) statistical data lines examined in the annual special report. The exceptions were as follows: d) After examination of the quarterly special report of the student aid portion for the quarter ended December 31, 2021, we noted a difference in the Item #5: ?The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms?. The total of students that received assistance aid reported was 443; however, the number per the student aid payroll reports examined was 460. Additionally, no support was available to determine if the Institution was timely and accurate in publicly posting the quarterly Student Aid Portion Report selected for testing. e) In one out of a sample of forty (40) disbursements of financial aid to students (2.5%) we noted that the payment made did not agree with the Institution's fund distribution plan to prioritize students with financial need. The aid in excess disbursed to that student was $200. Criteria 2 CFR 200.302 (a) establishes that each state must expend and account for the Federal award in accordance with state laws, and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.302 (b) (2) to (4) establish that 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. If a Federal awarding agency requires reporting on an accrual basis from a recipient that maintains its records on other than an accrual basis, the recipient must not be required to establish an accrual accounting system. This recipient may develop accrual data for its reports on the basis of an analysis of the documentation on hand. Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income, and interest and be supported by source documentation. Effective control over, and accountability for, all funds, property, and other assets. 2 CFR 200.303 (a) to (d) establish that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. 2 CFR 200.334 establishes that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Cause The cause of the deficiencies noted were due to the following situations: a) The source of information provided by the Institution related to the financial information was the G5 report. Such information is on a cash basis; therefore, financial information was not reported on an accrual basis of accounting which is the basis of accounting followed by the Institution. Additionally, the Institution did not appropriately design and maintained documentation and/or analysis performed to prepare and complete the financial information required to be reported in the quarterly and annual reports. b) Lack of recordkeeping controls and procedures to document and maintain the source of information used for the financial and statistical data required in the annual and quarterly special reports. c) The Institution used the student EFC per the ISIR/SAR available at the time of the distribution, even though, an ISIR with a valid EFC was not available since the student FAFSA application was selected for verification by USDE. After the Institution completed the verification the student EFC increased from 0 to 3676. Effect Noncompliance with the reporting requirements could lead to significant administrative actions by the grantor, including a reduction in the amounts to be awarded. It could also be interpreted as a failure to achieve the programs objectives. Questioned costs Likely questioned costs are less than $25,000. Identification as a Repeat Finding No repeated finding. Recommendation We recommend the Institution to establish adequate procedures and controls to ensure that financial and statistical data information is properly supported and detailed to allow adequate audit trail of the information. Establish adequate supervisory procedures to identify, in a reasonable period of time, deficiencies or possible deficiencies in the procedures or guidance established by management to ascertain that the Institution reports the information as required by grantors, and that accurate and adequate support is properly maintained. Views of Responsible Officials Refer to the Institutional comments included in the Corrective Action Plan.
Assistance listing program: Education Stabilization Fund - Higher Education Emergency Relief Fund (HEERF) Assistance Listing Number: 84.425E / 84.425F Award identification number: P425F204999 / P425E205418 Award period: September 29, 2020 to June 30, 2023 and July 23, 2020 to May 23, 2022 Federal agency: U.S. Department of Education Pass-through entity: N/A Category: Internal Control / Compliance Finding Type: Material Weakness Compliance requirement: Reporting Condition and context For testing internal controls and compliance with reporting requirements applicable to the HEERF programs, we inquired the Institution about the internal controls and procedures for determining the criteria and methodology used in compiling and reporting the data to be included in the annual and quarterly special reports. We requested a copy of the annual report for the calendar year 2021 and the quarterly reports for the quarter ended on December 31, 2021 related to the institutional aid portion and the student aid portion. As part of our procedures, we tested the method of distribution of grants to ascertain consistency with the method that was actually employed by the Institution to distribute emergency financial aid grants to students. After our examination and tests performed, we noted the following: a) The methodology used to compile the information in the annual report was based on the funds drawdowns which were based on disbursements rather than the actual program expenditures for the Institutional aid funds in accordance with GAAP. b) After examination of the institutional aid portion expenditures amounts reported in the annual special report for the calendar year ended December 31, 2021 to the support provided by the Institution, we noted that the total of institutional annual expenditures was understated by $7,160. c) From the sample of enrollment statistical data selected for verification to the source documents and/or information we noted several differences and were unable to identify some of the information in the source documents in nineteen (19) out of a sample of thirty (30) statistical data lines examined in the annual special report. The exceptions were as follows: d) After examination of the quarterly special report of the student aid portion for the quarter ended December 31, 2021, we noted a difference in the Item #5: ?The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms?. The total of students that received assistance aid reported was 443; however, the number per the student aid payroll reports examined was 460. Additionally, no support was available to determine if the Institution was timely and accurate in publicly posting the quarterly Student Aid Portion Report selected for testing. e) In one out of a sample of forty (40) disbursements of financial aid to students (2.5%) we noted that the payment made did not agree with the Institution's fund distribution plan to prioritize students with financial need. The aid in excess disbursed to that student was $200. Criteria 2 CFR 200.302 (a) establishes that each state must expend and account for the Federal award in accordance with state laws, and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.302 (b) (2) to (4) establish that 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. If a Federal awarding agency requires reporting on an accrual basis from a recipient that maintains its records on other than an accrual basis, the recipient must not be required to establish an accrual accounting system. This recipient may develop accrual data for its reports on the basis of an analysis of the documentation on hand. Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income, and interest and be supported by source documentation. Effective control over, and accountability for, all funds, property, and other assets. 2 CFR 200.303 (a) to (d) establish that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. 2 CFR 200.334 establishes that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Cause The cause of the deficiencies noted were due to the following situations: a) The source of information provided by the Institution related to the financial information was the G5 report. Such information is on a cash basis; therefore, financial information was not reported on an accrual basis of accounting which is the basis of accounting followed by the Institution. Additionally, the Institution did not appropriately design and maintained documentation and/or analysis performed to prepare and complete the financial information required to be reported in the quarterly and annual reports. b) Lack of recordkeeping controls and procedures to document and maintain the source of information used for the financial and statistical data required in the annual and quarterly special reports. c) The Institution used the student EFC per the ISIR/SAR available at the time of the distribution, even though, an ISIR with a valid EFC was not available since the student FAFSA application was selected for verification by USDE. After the Institution completed the verification the student EFC increased from 0 to 3676. Effect Noncompliance with the reporting requirements could lead to significant administrative actions by the grantor, including a reduction in the amounts to be awarded. It could also be interpreted as a failure to achieve the programs objectives. Questioned costs Likely questioned costs are less than $25,000. Identification as a Repeat Finding No repeated finding. Recommendation We recommend the Institution to establish adequate procedures and controls to ensure that financial and statistical data information is properly supported and detailed to allow adequate audit trail of the information. Establish adequate supervisory procedures to identify, in a reasonable period of time, deficiencies or possible deficiencies in the procedures or guidance established by management to ascertain that the Institution reports the information as required by grantors, and that accurate and adequate support is properly maintained. Views of Responsible Officials Refer to the Institutional comments included in the Corrective Action Plan.
Assistance listing program: Education Stabilization Fund - Higher Education Emergency Relief Fund (HEERF) Assistance Listing Number: 84.425E / 84.425F Award identification number: P425F204999 / P425E205418 Award period: September 29, 2020 to June 30, 2023 and July 23, 2020 to May 23, 2022 Federal agency: U.S. Department of Education Pass-through entity: N/A Category: Internal Control / Compliance Finding Type: Material Weakness Compliance requirement: Reporting Condition and context For testing internal controls and compliance with reporting requirements applicable to the HEERF programs, we inquired the Institution about the internal controls and procedures for determining the criteria and methodology used in compiling and reporting the data to be included in the annual and quarterly special reports. We requested a copy of the annual report for the calendar year 2021 and the quarterly reports for the quarter ended on December 31, 2021 related to the institutional aid portion and the student aid portion. As part of our procedures, we tested the method of distribution of grants to ascertain consistency with the method that was actually employed by the Institution to distribute emergency financial aid grants to students. After our examination and tests performed, we noted the following: a) The methodology used to compile the information in the annual report was based on the funds drawdowns which were based on disbursements rather than the actual program expenditures for the Institutional aid funds in accordance with GAAP. b) After examination of the institutional aid portion expenditures amounts reported in the annual special report for the calendar year ended December 31, 2021 to the support provided by the Institution, we noted that the total of institutional annual expenditures was understated by $7,160. c) From the sample of enrollment statistical data selected for verification to the source documents and/or information we noted several differences and were unable to identify some of the information in the source documents in nineteen (19) out of a sample of thirty (30) statistical data lines examined in the annual special report. The exceptions were as follows: d) After examination of the quarterly special report of the student aid portion for the quarter ended December 31, 2021, we noted a difference in the Item #5: ?The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms?. The total of students that received assistance aid reported was 443; however, the number per the student aid payroll reports examined was 460. Additionally, no support was available to determine if the Institution was timely and accurate in publicly posting the quarterly Student Aid Portion Report selected for testing. e) In one out of a sample of forty (40) disbursements of financial aid to students (2.5%) we noted that the payment made did not agree with the Institution's fund distribution plan to prioritize students with financial need. The aid in excess disbursed to that student was $200. Criteria 2 CFR 200.302 (a) establishes that each state must expend and account for the Federal award in accordance with state laws, and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.302 (b) (2) to (4) establish that 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. If a Federal awarding agency requires reporting on an accrual basis from a recipient that maintains its records on other than an accrual basis, the recipient must not be required to establish an accrual accounting system. This recipient may develop accrual data for its reports on the basis of an analysis of the documentation on hand. Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income, and interest and be supported by source documentation. Effective control over, and accountability for, all funds, property, and other assets. 2 CFR 200.303 (a) to (d) establish that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. 2 CFR 200.334 establishes that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Cause The cause of the deficiencies noted were due to the following situations: a) The source of information provided by the Institution related to the financial information was the G5 report. Such information is on a cash basis; therefore, financial information was not reported on an accrual basis of accounting which is the basis of accounting followed by the Institution. Additionally, the Institution did not appropriately design and maintained documentation and/or analysis performed to prepare and complete the financial information required to be reported in the quarterly and annual reports. b) Lack of recordkeeping controls and procedures to document and maintain the source of information used for the financial and statistical data required in the annual and quarterly special reports. c) The Institution used the student EFC per the ISIR/SAR available at the time of the distribution, even though, an ISIR with a valid EFC was not available since the student FAFSA application was selected for verification by USDE. After the Institution completed the verification the student EFC increased from 0 to 3676. Effect Noncompliance with the reporting requirements could lead to significant administrative actions by the grantor, including a reduction in the amounts to be awarded. It could also be interpreted as a failure to achieve the programs objectives. Questioned costs Likely questioned costs are less than $25,000. Identification as a Repeat Finding No repeated finding. Recommendation We recommend the Institution to establish adequate procedures and controls to ensure that financial and statistical data information is properly supported and detailed to allow adequate audit trail of the information. Establish adequate supervisory procedures to identify, in a reasonable period of time, deficiencies or possible deficiencies in the procedures or guidance established by management to ascertain that the Institution reports the information as required by grantors, and that accurate and adequate support is properly maintained. Views of Responsible Officials Refer to the Institutional comments included in the Corrective Action Plan.
Assistance listing program: Education Stabilization Fund - Higher Education Emergency Relief Fund (HEERF) Assistance Listing Number: 84.425E / 84.425F Award identification number: P425F204999 / P425E205418 Award period: September 29, 2020 to June 30, 2023 and July 23, 2020 to May 23, 2022 Federal agency: U.S. Department of Education Pass-through entity: N/A Category: Internal Control / Compliance Finding Type: Material Weakness Compliance requirement: Reporting Condition and context For testing internal controls and compliance with reporting requirements applicable to the HEERF programs, we inquired the Institution about the internal controls and procedures for determining the criteria and methodology used in compiling and reporting the data to be included in the annual and quarterly special reports. We requested a copy of the annual report for the calendar year 2021 and the quarterly reports for the quarter ended on December 31, 2021 related to the institutional aid portion and the student aid portion. As part of our procedures, we tested the method of distribution of grants to ascertain consistency with the method that was actually employed by the Institution to distribute emergency financial aid grants to students. After our examination and tests performed, we noted the following: a) The methodology used to compile the information in the annual report was based on the funds drawdowns which were based on disbursements rather than the actual program expenditures for the Institutional aid funds in accordance with GAAP. b) After examination of the institutional aid portion expenditures amounts reported in the annual special report for the calendar year ended December 31, 2021 to the support provided by the Institution, we noted that the total of institutional annual expenditures was understated by $7,160. c) From the sample of enrollment statistical data selected for verification to the source documents and/or information we noted several differences and were unable to identify some of the information in the source documents in nineteen (19) out of a sample of thirty (30) statistical data lines examined in the annual special report. The exceptions were as follows: d) After examination of the quarterly special report of the student aid portion for the quarter ended December 31, 2021, we noted a difference in the Item #5: ?The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms?. The total of students that received assistance aid reported was 443; however, the number per the student aid payroll reports examined was 460. Additionally, no support was available to determine if the Institution was timely and accurate in publicly posting the quarterly Student Aid Portion Report selected for testing. e) In one out of a sample of forty (40) disbursements of financial aid to students (2.5%) we noted that the payment made did not agree with the Institution's fund distribution plan to prioritize students with financial need. The aid in excess disbursed to that student was $200. Criteria 2 CFR 200.302 (a) establishes that each state must expend and account for the Federal award in accordance with state laws, and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.302 (b) (2) to (4) establish that 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. If a Federal awarding agency requires reporting on an accrual basis from a recipient that maintains its records on other than an accrual basis, the recipient must not be required to establish an accrual accounting system. This recipient may develop accrual data for its reports on the basis of an analysis of the documentation on hand. Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income, and interest and be supported by source documentation. Effective control over, and accountability for, all funds, property, and other assets. 2 CFR 200.303 (a) to (d) establish that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. 2 CFR 200.334 establishes that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Cause The cause of the deficiencies noted were due to the following situations: a) The source of information provided by the Institution related to the financial information was the G5 report. Such information is on a cash basis; therefore, financial information was not reported on an accrual basis of accounting which is the basis of accounting followed by the Institution. Additionally, the Institution did not appropriately design and maintained documentation and/or analysis performed to prepare and complete the financial information required to be reported in the quarterly and annual reports. b) Lack of recordkeeping controls and procedures to document and maintain the source of information used for the financial and statistical data required in the annual and quarterly special reports. c) The Institution used the student EFC per the ISIR/SAR available at the time of the distribution, even though, an ISIR with a valid EFC was not available since the student FAFSA application was selected for verification by USDE. After the Institution completed the verification the student EFC increased from 0 to 3676. Effect Noncompliance with the reporting requirements could lead to significant administrative actions by the grantor, including a reduction in the amounts to be awarded. It could also be interpreted as a failure to achieve the programs objectives. Questioned costs Likely questioned costs are less than $25,000. Identification as a Repeat Finding No repeated finding. Recommendation We recommend the Institution to establish adequate procedures and controls to ensure that financial and statistical data information is properly supported and detailed to allow adequate audit trail of the information. Establish adequate supervisory procedures to identify, in a reasonable period of time, deficiencies or possible deficiencies in the procedures or guidance established by management to ascertain that the Institution reports the information as required by grantors, and that accurate and adequate support is properly maintained. Views of Responsible Officials Refer to the Institutional comments included in the Corrective Action Plan.
Finding 2022-002 ? Reporting Federal Agency: U.S. Department of Health and Human Services Passthrough Entity: Illinois Department of Human Services Assistance Listing Number and Federal Program: 93.667 Social Services Block Grant Criteria: In accordance with 2 CFR 200.329, the Organization must submit performance reports at the interval required by the pass-through entity. The grant agreement with the Organization and the State of Illinois Department of Human Services requires quarterly performance reports be submitted no later than the 25th day of the month following the end of the quarter. Statement of Condition: The periodic performance report for the quarter ending December 31, 2021, was submitted February 16, 2022, or 22 days late. Statement of Cause: After discussion with personnel, it was determined that notification of the readiness to submit the quarterly performance report was not communicated in a timely manner. Statement of Effect: Noncompliance with the reporting requirements can put the Organization at risk of being placed on the Illinois Stop Payment List and final payment being withheld. Questioned Costs: No questioned costs were identified.Perspective Information: This appears to be an isolated incident. All other required financial and performance reporting was completed accurately and timely. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend a review be put in place to ensure all required reporting is completed and timely submitted to ensure compliance with grant requirements. All notifications received regarding the grant should be effectively communicated to all personnel involved in the grant. Views of Responsible Officials: Processes will be implemented to review and monitor grant reporting requirements utilizing tracking sheets and corresponding reminders with reporting due dates. These processes will assist the Organization to better complete and submit reports in accordance with grant requirements. See Corrective Action Plan.
2022-001 Direct Programs ? Department of Education Federal Financial Assistance Listing: 84.425E, 84.425F COVID ? 19: Higher Education Emergency Relief Student Aid Portion, COVID ? 19: Higher Education Emergency Relief Institutional Portion Reporting Significant Deficiency in Internal Controls over Compliance Criteria: The CARES Act 18004(e), CRRSAA 314(e), 2 CFR section 200.328 and 2 CFR section 200.329 requires an institution receiving funds under HEERF I, HEERF II, and HEERF III to submit a report to the secretary, at such time in such a manner as the secretary may require. Condition: During our testing over the reporting for the HEERF student and institutional Funds, there were four reports out 10 reports that were required to be filed during the fiscal year that were not filed within the required timeframe. Cause: The University did not have an adequate control system in place to ensure that the reports required to be filed for HEERF student and institutional funds were filed timely. Effect: The reports required to be filed for the HEERF Student and Institutional funds were not filed timely. Questioned Costs: None Context/Sampling: All reports required to be filed during the year for the HEERF student and institutional funds were tested (a total of 10 reports were filed during the fiscal year). Repeat Finding from Prior Year(s): Yes. Recommendation: Management should have a process in place to ensure that all reports are filed within the required timeframe. Views of Responsible Officials: Management agrees with the finding. Views of Responsible Officials: Management agrees with the finding.
Condition ? As directed by the U.S. Department of Education for all HEERF funding, Mount Carmel College of Nursing (?the College?) is required to prepare quarterly reports for Institutional portions and conspicuously post them on the College?s website in a timely manner. During the audit it was determined that the College did not complete quarterly reports for Q3 and Q4 for fiscal year ending June 30, 2022, for HEERF Institutional portions of funding and hence no public postings were made available on the College?s website. Criteria ? The U.S. Department of Education, under sections 2 CFR 200.328 and 2 CFR 200.329, requires that each quarterly reporting form for both HEERF Institutional and Student Aid Portion must be completed and posted to the institution?s primary website no later than 10 days after the end of each calendar quarter. Cause ? The Senior Finance Director (report preparer) and Director of Financial Aid (report reviewer) for the College both resigned in March 2022 and April 2022, respectively. As a result, the quarterly reports were not prepared within the required timeframe. Effect ? Neither the Institutional nor Student Aid Portion quarterly reporting forms were prepared and posted for Q3 and Q4 of the current fiscal year. This results in noncompliance and could cause a negative impact on future fundings for the College. Questioned costs ? $0 Context ? Two out of four quarterly reports for the fiscal year ended June 30, 2022 were not completed. Repeat Finding from Prior Year ? No Recommendation ? The College?s business administration should have a plan in place to ensure that quarterly reports are prepared timely and have backup plans in place in the event that the preparer or reviewer are not available.
Criteria In accordance with the Uniform Guidance 2 CFR 200.302(b-2), ?The financial management system of each non-Federal entity must provide for accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329.? Condition We noted the following during our audit. 1. Charter School grant expenses amounting to $192,517 were recorded as General Fund expense instead of as a revenue and expense in the Special Revenue Fund. Of which $70,240 were recorded as General Fund expense instead of as a revenue and expense in the Special Revenue Fund. A prior period adjustment was required to reimburse the General Fund for the grant expense. 2. Charter School grant expenses incurred and claimed during the fiscal year ended June 30, 2022 amounting to $212,619 were recorded in the General Fund and not in the Special Revenue Fund. Context Details of the reimbursements for the grant did not agree with the details recorded in the Special Revenue Fund. Cause There was delay in the reconciliation of reimbursement requests with expenditures recorded in the Special Revenue Fund and General Fund. Effect Various journal entries were recorded and trial balance revisions were made to correct recorded expenses in the Special Revenue Fund, including a prior period adjustment of $70,240 to increase net position of the General Fund net position at July 1, 2021. Questioned Cost None. Recommendation The Charter School should ensure that there is a smooth coordination between the reimbursement and recording functions. The Charter School should also ensure timely reconciliation of reimbursement reports and records.