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.
FINDING 2022-004 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425C Federal Award Number and Year (or Other Identifying Number): S425C200018 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation filed the four Elementary and Secondary School Emergency Relief (ESSER) and the two Governor's Emergency Education Relief (GEER) annual data reports due during the audit period. However, for GEER I, Year 2, the School Corporation reported $56,149 in expenditures although the School Corporation had $314,301 in expenditures from the GEER fund during the Year 2 reporting period. The lack of internal controls and noncompliance was isolated to the GEER Year 2 annual report. INDIANA STATE BOARD OF ACCOUNTS 21 LAPORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not developed a system of internal controls that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2022-002 ? Significant Deficiency, Reporting Federal Assistance Listing No. 84.425F U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) Criteria: 2 CFR section 200.328 and 2 CFR section 200.329 requires grantees to submit quarterly reports for both student and institutional portions along with an annual report to the Department of Education. Condition: In our nonstatistical testing of 4 of the quarterly reports and 1 annual report, it was noted that costs for 2 of the quarterly reports were presented cumulatively, rather than separately by quarter which is based on guidance from the Department of Education. Cause: Management charged with oversight over the federal grant reported costs in a cumulative manner, rather than separately by quarter which is based on guidance from the Department of Education. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable Context: 1 student portion and 1 institutional portion quarterly report, while filed timely, had costs reported presented cumulatively, rather than separately by quarter which is based on guidance from the department of Education. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management report costs on the student and institutional quarterly reports presented separately by quarter, rather than cumulatively. Views Of Responsible Officials/Corrective Action Plan (Unaudited): See the corrective action plan provided by management included with this report. Completion Date: June 2023 Contact Person: Kris Pace, Controller
2022 ? 004: HEERF Reporting Federal Agency: U.S. Department of Education Federal Program Name: (COVID-19) Higher Education Emergency Relief Fund Assistance Listing Number: 84.425F, 84.425M Federal Award Identification Number and Year: P425E204430-2020, P425M201006-20A-2020 Award Period: 84.425F ? May 14, 2020 to June 30, 2023 / 84.425M ? August 5, 2020 to June 30, 2023 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 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 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, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: The University filed the annual report on May 12th, 2022, which was two (2) days later than the requirement to complete by May 10th, 2022. Questioned costs: There are no questioned costs. Context: In performing our audit, we noted that the University had not filed the annual report, with the appropriate supporting documentation, in accordance with the stated criteria. Cause: The University?s internal controls failed to detect that the annual report was not filed by the due date in the stated criteria. Effect: The University was not in compliance with the requirement to file the annual report by the due date in the stated criteria. Repeat Finding: No Recommendation: We recommend the University review its policies and procedures for the filing of the HEERF to ensure that there is sufficient time in the process to meet the due date in accordance with the stated criteria. The evidence of submission should include the original supporting documentation for the information published. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: HEERF Reporting Federal Agency: U.S. Department of Education Federal Program Name: (COVID-19) Higher Education Emergency Relief Fund Assistance Listing Number: 84.425F, 84.425M Federal Award Identification Number and Year: P425E204430-2020, P425M201006-20A-2020 Award Period: 84.425F ? May 14, 2020 to June 30, 2023 / 84.425M ? August 5, 2020 to June 30, 2023 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 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 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, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: The University filed the annual report on May 12th, 2022, which was two (2) days later than the requirement to complete by May 10th, 2022. Questioned costs: There are no questioned costs. Context: In performing our audit, we noted that the University had not filed the annual report, with the appropriate supporting documentation, in accordance with the stated criteria. Cause: The University?s internal controls failed to detect that the annual report was not filed by the due date in the stated criteria. Effect: The University was not in compliance with the requirement to file the annual report by the due date in the stated criteria. Repeat Finding: No Recommendation: We recommend the University review its policies and procedures for the filing of the HEERF to ensure that there is sufficient time in the process to meet the due date in accordance with the stated criteria. The evidence of submission should include the original supporting documentation for the information published. Views of responsible officials: There is no disagreement with the audit finding.
FINDING 2022-002 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, Contract #46504 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor's Emergency Education Relief (GEER) annual data reports (Reports) were complete and accurately submitted. The reports were prepared and submitted by one employee without any oversight, review, or approval process in place to prevent, or detect and correct, errors. Supporting documentation provided did not support the Full Time Equivalent (FTE) position amounts reported on the ESSER I, Yr. 1 and GEER I, Year 1 reports. 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 Management had not developed or implemented a system of internal control that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, Contract #46504 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor's Emergency Education Relief (GEER) annual data reports (Reports) were complete and accurately submitted. The reports were prepared and submitted by one employee without any oversight, review, or approval process in place to prevent, or detect and correct, errors. Supporting documentation provided did not support the Full Time Equivalent (FTE) position amounts reported on the ESSER I, Yr. 1 and GEER I, Year 1 reports. 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 Management had not developed or implemented a system of internal control that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, Contract #46504 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor's Emergency Education Relief (GEER) annual data reports (Reports) were complete and accurately submitted. The reports were prepared and submitted by one employee without any oversight, review, or approval process in place to prevent, or detect and correct, errors. Supporting documentation provided did not support the Full Time Equivalent (FTE) position amounts reported on the ESSER I, Yr. 1 and GEER I, Year 1 reports. 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 Management had not developed or implemented a system of internal control that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, Contract #46504 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor's Emergency Education Relief (GEER) annual data reports (Reports) were complete and accurately submitted. The reports were prepared and submitted by one employee without any oversight, review, or approval process in place to prevent, or detect and correct, errors. Supporting documentation provided did not support the Full Time Equivalent (FTE) position amounts reported on the ESSER I, Yr. 1 and GEER I, Year 1 reports. 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 Management had not developed or implemented a system of internal control that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, Contract #46504 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor's Emergency Education Relief (GEER) annual data reports (Reports) were complete and accurately submitted. The reports were prepared and submitted by one employee without any oversight, review, or approval process in place to prevent, or detect and correct, errors. Supporting documentation provided did not support the Full Time Equivalent (FTE) position amounts reported on the ESSER I, Yr. 1 and GEER I, Year 1 reports. 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 Management had not developed or implemented a system of internal control that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Higher Education Stabilization Fund Reporting Other Matter DEPARTMENT OF EDUCATION ALN #: 84.425E Education Stabilization Fund Federal Award Identification #: P425E202939 Condition: The University did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for the American Rescue Plan (ARP) student portion expended. Criteria: 86 FR 262132, CFR 200.329. For each student grant disbursement made, the University is required to report quarterly to their website a summary of how the funds were allocated and disbursed. Questioned Costs: None Context: During the audit, it was noted that while the University had appropriately disclosed the required CARES Act and CRRSAA Act reporting and ARP institutional reporting for HEERF institutional funds, the ARP student emergency grant disbursements were not disclosed on their website. The University corrected and amounts were posted to the website before the audit was finalized. Cause: There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: n/a Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E203029, P425F200396, P425N200726 Federal Award Year: June 30, 2022 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, a number of the HEERF section (a)(1) and (a)(3) amounts reported as institutional portion spending were incorrect based on supporting documentation provided by the University. In addition, for the fourth quarter 2021 (quarter ending December 31, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(1) student portion of HEERF awarded to the University on the section (a)(3) line, when the amount on the section (a)(3) line should have been the total Fund for the Improvement of Postsecondary Education (FIPSE) funding awarded to the University. Also, for the quarterly student portion reports, the University reported the incorrect number of students who were eligible to receive a CRRSAA emergency financial aid grant during the fall of 2021. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed, turnover during the year in key personnel associated with preparing and reviewing the reports, and a transposition error. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management?s Response: The University has updated their procedure for preparing and reviewing the required reports and have established a team from the finance department to discuss issues that arise. The team will handle the identified discrepancies through their resolution. The team will meet at least monthly, and as requested by the Senior Accountant of Grants or the Director of Finance and Accounting (DFA). The team is receiving training on procedures, guidelines, and terminology to ensure accuracy on completed reports to ensure compliance. The updated procedure is that the Senior Accountant of Grants will prepare the quarterly and annual reports based on data provided in the accounting system and from the Office of Financial Aid and assure that the reported data ties to the University?s records. The completed reports will be reviewed by the Director of Finance and Accounting. When needed, the finance team will meet to handle apparent discrepancies. Approved reports will be returned by the DFA to the Senior Accountant who will then post the reports for public viewing and submit a copy to the funder.
Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E203029, P425F200396, P425N200726 Federal Award Year: June 30, 2022 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, a number of the HEERF section (a)(1) and (a)(3) amounts reported as institutional portion spending were incorrect based on supporting documentation provided by the University. In addition, for the fourth quarter 2021 (quarter ending December 31, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(1) student portion of HEERF awarded to the University on the section (a)(3) line, when the amount on the section (a)(3) line should have been the total Fund for the Improvement of Postsecondary Education (FIPSE) funding awarded to the University. Also, for the quarterly student portion reports, the University reported the incorrect number of students who were eligible to receive a CRRSAA emergency financial aid grant during the fall of 2021. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed, turnover during the year in key personnel associated with preparing and reviewing the reports, and a transposition error. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management?s Response: The University has updated their procedure for preparing and reviewing the required reports and have established a team from the finance department to discuss issues that arise. The team will handle the identified discrepancies through their resolution. The team will meet at least monthly, and as requested by the Senior Accountant of Grants or the Director of Finance and Accounting (DFA). The team is receiving training on procedures, guidelines, and terminology to ensure accuracy on completed reports to ensure compliance. The updated procedure is that the Senior Accountant of Grants will prepare the quarterly and annual reports based on data provided in the accounting system and from the Office of Financial Aid and assure that the reported data ties to the University?s records. The completed reports will be reviewed by the Director of Finance and Accounting. When needed, the finance team will meet to handle apparent discrepancies. Approved reports will be returned by the DFA to the Senior Accountant who will then post the reports for public viewing and submit a copy to the funder.
Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E203029, P425F200396, P425N200726 Federal Award Year: June 30, 2022 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, a number of the HEERF section (a)(1) and (a)(3) amounts reported as institutional portion spending were incorrect based on supporting documentation provided by the University. In addition, for the fourth quarter 2021 (quarter ending December 31, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(1) student portion of HEERF awarded to the University on the section (a)(3) line, when the amount on the section (a)(3) line should have been the total Fund for the Improvement of Postsecondary Education (FIPSE) funding awarded to the University. Also, for the quarterly student portion reports, the University reported the incorrect number of students who were eligible to receive a CRRSAA emergency financial aid grant during the fall of 2021. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed, turnover during the year in key personnel associated with preparing and reviewing the reports, and a transposition error. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management?s Response: The University has updated their procedure for preparing and reviewing the required reports and have established a team from the finance department to discuss issues that arise. The team will handle the identified discrepancies through their resolution. The team will meet at least monthly, and as requested by the Senior Accountant of Grants or the Director of Finance and Accounting (DFA). The team is receiving training on procedures, guidelines, and terminology to ensure accuracy on completed reports to ensure compliance. The updated procedure is that the Senior Accountant of Grants will prepare the quarterly and annual reports based on data provided in the accounting system and from the Office of Financial Aid and assure that the reported data ties to the University?s records. The completed reports will be reviewed by the Director of Finance and Accounting. When needed, the finance team will meet to handle apparent discrepancies. Approved reports will be returned by the DFA to the Senior Accountant who will then post the reports for public viewing and submit a copy to the funder.
FINDING 2022-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation's to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation completed and submitted four annual Data Collection reports (Reports) for the Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reports tested, the Reports were not supported by the unit's records. The financial information provided did not agree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports. Additionally, four of six key line items selected for testing could not be traced to supporting documentation. 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. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 2 CFR 200.334 states in part: "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. . . ." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause Management had not developed a system of internal control that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective internal control system, as well as retain documentation to support reports, prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls, as well as retain documentation, to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation's to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation completed and submitted four annual Data Collection reports (Reports) for the Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reports tested, the Reports were not supported by the unit's records. The financial information provided did not agree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports. Additionally, four of six key line items selected for testing could not be traced to supporting documentation. 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. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 2 CFR 200.334 states in part: "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. . . ." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause Management had not developed a system of internal control that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective internal control system, as well as retain documentation to support reports, prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls, as well as retain documentation, to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation's to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation completed and submitted four annual Data Collection reports (Reports) for the Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reports tested, the Reports were not supported by the unit's records. The financial information provided did not agree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports. Additionally, four of six key line items selected for testing could not be traced to supporting documentation. 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. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 2 CFR 200.334 states in part: "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. . . ." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause Management had not developed a system of internal control that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective internal control system, as well as retain documentation to support reports, prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls, as well as retain documentation, to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation's to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation completed and submitted four annual Data Collection reports (Reports) for the Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reports tested, the Reports were not supported by the unit's records. The financial information provided did not agree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports. Additionally, four of six key line items selected for testing could not be traced to supporting documentation. 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. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 2 CFR 200.334 states in part: "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. . . ." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause Management had not developed a system of internal control that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective internal control system, as well as retain documentation to support reports, prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls, as well as retain documentation, to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation's to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation completed and submitted four annual Data Collection reports (Reports) for the Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reports tested, the Reports were not supported by the unit's records. The financial information provided did not agree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports. Additionally, four of six key line items selected for testing could not be traced to supporting documentation. 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. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 2 CFR 200.334 states in part: "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. . . ." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause Management had not developed a system of internal control that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective internal control system, as well as retain documentation to support reports, prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls, as well as retain documentation, to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-006 Subject: Title I Grants to Local Educational Agencies - Reporting Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation did not have an internal control over the final expenditure reports submitted during the audit period. The Treasurer submitted the report without a documented review or oversight in place to prevent, or detect and correct, errors on the reports. The School Corporation must report all required set asides manually on the final expenditure report submitted to the Indiana Department of Education. Grant award S010A200014 had a required set-aside for parental involvement; however, a set aside was not reported on the final expenditure report. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the S010A200014 grant award. 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) (Uniform Guidance) 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 ?? 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) 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 Management had not designed or implemented a system of internal controls that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective system of internal controls enabled noncompliance to go undetected. Noncompliance with the grant agreement and Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-006 Subject: Title I Grants to Local Educational Agencies - Reporting Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation did not have an internal control over the final expenditure reports submitted during the audit period. The Treasurer submitted the report without a documented review or oversight in place to prevent, or detect and correct, errors on the reports. The School Corporation must report all required set asides manually on the final expenditure report submitted to the Indiana Department of Education. Grant award S010A200014 had a required set-aside for parental involvement; however, a set aside was not reported on the final expenditure report. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the S010A200014 grant award. 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) (Uniform Guidance) 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 ?? 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) 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 Management had not designed or implemented a system of internal controls that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective system of internal controls enabled noncompliance to go undetected. Noncompliance with the grant agreement and Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-009 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The annual Elementary and Secondary School Emergency Relief (ESSER) annual data collection reports (Reports) were prepared by the Treasurer and reviewed and approved by the Director of Curriculum prior to submission; however, the review process in place did not prevent, or detect and correct, errors. Of the six reports tested, four (ESSER I, Year 1 and Year 2, ESSER II, Year 1, and ESSER III Year 1) were not supported by the School Corporation's records. Key line items selected for review and verification were determined to be incorrectly reported on the ESSER I, Year 1 report as well as omitted from the ESSER I, Year 2, ESSER II, Year 1, and ESSER III, Year 1 reports. 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 200.333 (Uniform Guidance) states in part: "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. . . ." 2 CFR 200.334 (Revised Uniform Guidance) states in part: "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. . . ." 2 CFR 200.302(b) (Uniform Guidance) 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 ?? 200.327 Financial reporting . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) 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. . . . (3) Records that identify adequately the source and application of funds for federallyfunded 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. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not established a system of internal controls that would have ensured compliance with the Equipment and Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.