2 CFR 200.329(c)(1) states that non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly, using a form or format authorized by the Office of Budget and Management (OBM). Recipients must use the standard financial reporting forms or such other forms as may be authorized by OMB (approval is indicated by an OMB paperwork control number on the form) when reporting to the Federal awarding agency. Each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the Federal awarding agency. Entities are required to submit a Project and Expenditure Report annually. Reported expenditures on the draw down reports for 2024 did not agree with supporting invoices paid by the Village. The Village, on two occasions, received monies prior to the bills being paid. Therefore, draws were being completed prior to the expenditures happening. Additionally, the Project and Expenditure report for 2024 which was due by April 30, 2025, was not submitted. By not properly filing the required reports, the Village is in noncompliance with the requirements set forth by the U.S. Department of Treasury. This could result in the Treasury not fully being aware of how the Village is utilizing the funding in determining if the Village is following other requirements and using the funding properly. The Village should add additional procedures or controls to ensure all components of reporting federal expenditures are accurately reported.
2 CFR § 3002 gives regulatory effect to the Department of Homeland Security for 2 C.F.R. § 200.329(c) which states, in part, reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. The final performance report submitted by the non-Federal entity and/or pass through entity must be due no later than 120 calendar days after the period of performance end date. Due to deficiencies in policies and procedures over reporting compliance we noted the following: • The required Programmatic Performance Report (PPR) for the period of July 1, 2024 through December 31, 2024 was not submitted on the FEMA Go website; • The required Federal Financial Report (SF-425) for the period of January 1, 2024 through June 30, 2024 was not submitted on the FEMA Go website; and • Two of the three required Federal Financial Reports (SF-425) were submitted after the due date (one three days late, one over four months late). Failure to prepare and submit federal grant reports could result in the City not receiving the reimbursements that it is entitled to. The City should implement policies and procedures to help ensure that federal grant reports are completed and submitted by the required date.
2 CFR 1000.10 gives regulatory effect to Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards set forth at 2 CFR Part 200 for the Department of Treasury. 2 CFR 200.329(c)(1) states, that non-Federal entities must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Reports submitted quarterly must be due no later than 30 calendar days after the reporting period. 31 CFR § 35.4(c) requires, in part, recipients, during the period of performance, to provide the Secretary of the U.S. Department of Treasury (the Treasury) periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. For the Coronavirus State and Local Fiscal Recovery Funds, the Treasury issued the Final Rule, which clarified deadlines relating to Compliance and Reporting. The Treasury’s Compliance and Reporting guidance states that metropolitan cities and counties with a population below 250,000 residents that are allocated less than $10 million in State and Local Fiscal Recovery funding and non-entitlement units that are allocated less than $10 million in State and Local Fiscal Recovery funding are required to submit annual Project and Expenditure Reports. It further states annual reports will cover one calendar year and must be submitted to the Treasury by April 30th. The City’s annual Project and Expenditure Report was required to be submitted to the Treasury by April 30, 2024, however, was not submitted until June 20, 2024. The City’s failure to submit the required Project and Expenditure Report by the required date was due to lack of internal control over reporting for the program. Failure to have proper controls in place to ensure timely and accurate submission of Project and Expenditure Reports could result in the Treasury taking action against the City for failure to comply with programmatic requirements. The City should implement policies and procedures and have controls in place to ensure the Project and Expenditure Report is accurate and filed by the required due date to ensure compliance with their grantor's requirements.
2 CFR § 1000.10 gives regulatory effect to Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200 for the Department of Treasury. 2 CFR 200.329(c)(1) states that non-Federal entities must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. 31 CFR 35.4(c) requires recipients, in part, during the period of performance, to provide the Secretary of the U.S. Department of Treasury periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. The U.S. Department of Treasury provided supplementary information on reporting requirements in its interim final rule for State and Local Fiscal Recovery Funds for 31 CFR Part 35 and provided further guidance in its Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guide. The City submitted the required SLFRF Program Reports; however, possibly due to the failure of an existing Control(s), only two out of three (sixty-seven percent) were submitted timely. Reporting errors could adversely affect future grant awards. An additional control(s) and/or additional procedure(s) should be implemented to help ensure accuracy of the reports and that reports are submitted timely as required.
2 CFR 1000.10 gives regulatory effect to the Department of Treasury for 2 CFR 200.329 which states the recipient is responsible for oversight of the Federal Award. The recipient must monitor its activities under Federal Awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient must cover each program, function or activity. Compliance and Reporting Guidance for the program states that Project and Expenditure Reports are to be submitted by April 30th, 2022 and then annually thereafter. Project and Expenditures Reports are also to include current and cumulative obligations and current and cumulative expenditures. The following errors were noted in the Project and Expense Report for the period April 1, 2024 through March 31, 2025: Gallia County ARPA Project Identification Number 2023-01 current period expenditures and obligations were overstated $207,622 and cumulative expenditures and obligations were overstated $9,258. Gallia County ARPA Project Identification Number 2024-1 current period expenditures were overstated $259.489 and cumulative expenditures and obligations were understated $1,149,079. Gallia County ARPA Project Identification Number 2024-01 current and cumulative expenditures were understated $502,560.81, current period obligations were overstated $133,176, and cumulative obligations were understated $508,174 in an attempt to compensate for prior period errors. Gallia County Project Identification Number 2021-03 current expenditures and current obligations were overstated $43,254. Gallia County Project Identification Number 2021-09 current expenditures and current obligations were overstated $98,131 and cumulative expenditures and cumulative obligations were overstated $447,793. Gallia County Project Identification Number 2022-05 current expenditures and obligations were overstated $29,909. Gallia County Project Identification Number 2022-06 current expenditures were overstated $417,885 and cumulative expenditures and cumulative obligations were overstated $253,499. Gallia County Project Identification Number 2022-07 current expenditures were overstated $7,590 and cumulative expenditures and cumulative obligations were overstated $245,909. Gallia County Project Identification Number 2022-08 current expenditures were overstated $14,264 and cumulative expenditures and cumulative obligations were overstated $231,645. Gallia County Project Identification Number 2022-00 current expenditures were overstated $519 and cumulative expenditures and cumulative obligations were overstated $231,645. Gallia County Project Identification Number 2022-01 current expenditures were overstated $5,708 and cumulative expenditures and obligations were overstated $225,865. Gallia County Project Identification Number 2022-10 current expenditures and current obligations were overstated $214,189 and cumulative expenditures and cumulative obligations were overstated $11,676. Many of the above errors were a result of trying to fix past reporting errors and reporting prior period expenditures as current period expenditures. The County should ensure they are following all federal requirements and reporting amounts supported by the underlying County ledgers.
2 CFR 1000.10 provides that, except for the deviations set forth elsewhere in this Part, the Department of Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards set forth at 2 CFR Part 200. 2 CFR 200.302 states, in part, 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. 2 CFR 200.329(c)(1) states that non-Federal entities must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Reports submitted quarterly must be due no later than 30 calendar days after the reporting period. 31 CFR 35.4(c) requires recipients, in part, during the period of performance, to provide the Secretary of the U.S. Department of Treasury periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. The U.S. Department of Treasury provided supplementary information in its 2021 interim final rule on reporting requirements for State and Local Fiscal Recovery Funds for 31 CFR Part 35 and provided further guidance in its Project and Expenditure Report User Guide for State and Local Fiscal Recovery Funds. The 2021 interim rule supplementary information, part VIII states that counties will be required to submit quarterly Project and Expenditure reports through the end of the award period on December 31, 2026. The Department of Treasury’s Project and Expenditure Report User Guide provides, in part, that counties with a population that exceeds 250,000 residents must submit a Project and Expenditure Report by January 31, 2022 and then the last day of the month after the end of each quarter thereafter. The County did not have proper internal controls in place to ensure the timely and accurate submission of the Project and Expenditure Reports. During testing of Project and Expenditure Reports for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds (AL #21.027), we noted that: • The County did not submit the Project and Expenditure Reports for the second and fourth quarters by the required deadlines of July 31, 2024 and January 31, 2025, respectively. • On the first quarter Project and Expenditure Report, the County understated current period expenditures by $1,041,688, understated cumulative expenditures by $11,564,350, and understated cumulative obligations by $1,407,879. Similarly, on the third quarter Project and Expenditure Report, the County understated current period expenditures by $385.732, understated the cumulative expenditures by $13,169,950, and understated cumulative obligations by $1,407,879. Failure to have the proper controls in place to ensure the timely and accurate submission of the Project and Expenditure Reports could result in Treasury taking action against the County for failure to comply with programmatic requirements. The County should implement and have controls in place to ensure the quarterly Project and Expenditure Reports are accurate and filed by the required due dates.
ALN 14.251 Finding #2024‐009 Untimely or Incomplete Performance and Financial Reporting Repeat Finding: No Condition: The Organization did not submit required federal performance and financial reports in accordance with federal deadlines. Specifically, several required reports were either not completed, or were submitted after the required due dates set forth in the grant agreements. In some instances, supporting documentation was incomplete or insufficient. Criteria: Per 2 CFR 200.328 and 2 CFR 200.329, recipients of federal awards are required to submit performance and financial reports as required by the awarding agency. Reports must be accurate, complete, and submitted timely, in accordance with the terms and conditions of the award. Timely reporting allows federal agencies to monitor progress and ensure funds are used for authorized purposes. Cause: The Organization did not have adequate internal controls to track reporting due dates or ensure that reports were completed, reviewed, and submitted on time. Effect: Failure to submit complete and timely reports represents noncompliance with Uniform Guidance requirements and the terms of the federal awards and increases risk relating to the ability of the federal oversight agency to monitor the grant. Questioned Costs: None noted. Perspective Information: Performance and financial reports for each semi‐annual period were not submitted timely. Recommendation: We recommend that the Organization implement internal controls to ensure all required federal reports are completed accurately and submitted on time. Reporting Views of Responsible Officials: The Organization agrees with the finding. Procedures are being implemented to ensure all reports are provided to the Organization to ensure compliance with the federal grants.
2 CFR § 200.329(c)(1) requires the recipient or subrecipient must submit performance reports as required by the Federal award. Ohio Department of Development Water and Wastewater Infrastructure Program Grant Agreement, Exhibit II, Reporting indicates Grantee shall provide the documents listed below by the date(s) specified herein or to be determined by the Grantor. Grantor shall provide a format for these documents and shall instruct the Grantee in the proper completion of such documents. 2. Program Reports: Program reports must be submitted on a quarterly basis. Program reports must be submitted by close of business, on the second Friday at the end of each quarter. Program reports must include the following information: a. Narrative summary of use of funds during the reporting period b. Narrative describing promoting equitable outcomes. Describe efforts used to promote equitable outcomes, including how projects were implemented with equity in mind. c. Narrative describing community engagement d. Labor Practices: Describe workforce practices on projects implemented. How is the project using strong labor standards to promote effective and efficient delivery of high-quality infrastructure e. Project Construction Start Date (if applicable) f. Project Operations date g. National Pollutant Discharge Elimination System (NPDES} Permit Number (if applicable} h. Public Water System (PWS) ID Number (if applicable) i. Information on Matching funds utilized during the reporting period (i.e., source, amount and uses) 3. Final Report: A final project report must be submitted 15 days after the end of this agreement. The final report must include the following information: a. Number of new households who have access to public water or centralized sewer system b. Number of public and private service lines replaced c. Number of home sewage treatment systems replaced The Village completed their waterline and household lead line replacement project during the audit period, spending all $1,412,472 of the grant funds during 2024. However, the Village did not complete quarterly program reports during the year, nor the Final Report when the project was completed. We have modified our opinion accordingly. By not submitting the required reports as required by the grant agreement, the Village could adversely affect future grant awards. The Village should develop controls and procedures to help ensure the reports are filed with the Ohio Department of Development as required by 2 CFR § 200.329(c)(1) and the grant agreement.
2 CFR § 1000.10 gives regulatory effect to the Department of Treasury for 2 CFR 200.329(c)(1) which states in part, that non-federal entities must submit performance reports at least annually but not more frequently than quarterly. Recipients must use the standard financial reporting forms or such other forms as may be authorized by the Office of Management and Budget (OMB) (approval is indicated by an OMB paperwork control number on the form) when reporting to the Federal awarding agency. Each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the Federal awarding agency. Due to deficiencies in internal controls over reporting, the following errors were noted: • The Village did not accurately report current expenditures on the Project and Expenditure report in the amount of $218,642. • The Project and Expenditure report for Reporting Period ended March 31, 2025 was also not filed by the required due date. • The Village did not accurately report current expenditures on the Project and Expenditure report in the amount of $25,322 for the reporting period ended March 31, 2025. • In addition to these issues, the Village was also required to submit Program Reports on a quarterly basis by close of business on the second Friday at the end of each quarter and a final project report to be submitted 15 days after the end of the agreement (December 31, 2024) to the Ohio Department of Development (ODOD) for their infrastructure grant. The Village did not submit the reports in a timely manner as they were submitted in November 2025. By not properly filing the required reports with accurate underlying support, the Village is not in noncompliance with the requirements set forth by the U.S. Department of Treasury and requirements set forth by the Ohio Department of Development. This could result in the Treasury not fully being aware of how the Village is utilizing the funding in determining if the Village is following other requirements and using the funding properly. The Village should establish and implement additional controls to ensure all components of reporting federal expenditures are accurately reported in a timely manner.
Name of Federal Agency U.S. Department of Housing and Urban Development Pass-through the Puerto Rico Housing Finance Authority Federal Program Community Development Block Grant - Disaster Recovery Assistance Listing Number 14.228 Category Significant Deficiency and Noncompliance Compliance Requirement Reporting Criteria 2 CFR Part 200.329 (c)(i) established that the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually normore frequent than quarterly except in unusual circumstances, for example where more frequent reportingis necessary for the effective monitoring of the Federal award or could significantly affect programoutcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due nolater than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or passthrough entity may require annual reports before the anniversary dates of multiple year Federal awards. As per agreement with the Organization Part IV (b) established that the Authority shall submit regular monthly progress reports to the Puerto Rico Department of Housing (PRDOH), on the form and with the content to be specified and required by the PRDOH. The PRDOH will later notify the Authority in writing the guidelines and requirements applicable to the submittal of the monthly progress reports, and such notification shall be deemed incorporated by reference to this Agreement. As defined by PRDOH, the submission of progress reports must occur within five (5) days after the end of each month. Condition During our procedures performed to determine compliance with reporting requirements, we noted that the progress reports were not submitted on time to Puerto Rico Department of Housing (PRDOH). Cause and Effect Noncompliance with the reporting requirements could lead to significant administrative actions by the grantor, including a reduction in the amounts to be awarded. In addition, it prevents the grantor from monitoring the performance of the program and could be interpreted as a failure to achieve program objectives. Questioned Cost None Recommendation The Organization shall ensure effective supervision over its reporting processes to guarantee the timely preparation and submission of progress reports. It is advised that the Organization prioritize providing comprehensive training to personnel responsible for preparing, reviewing, and approving performance reports. This training should focus on equipping them with the necessary skills and knowledge to include all relevant data elements and adhere to deadlines consistently. Views of Responsible Officials Management of the Organization agrees with this finding. For details of the actions to be taken, refer to the Corrective Action Plan (CAP) section in this report. Responsible Person José Carrasquillo Delgado Finance Director
NONCOMPLIANCE AND MATERIAL WEAKNESSES 2 CFR 1000.10 provides that, except for the deviations set forth elsewhere in this Part, the Department of Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards set forth at 2 CFR Part 200. 2 CFR 200.302(b)(2) states, in part, 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. 2 CFR 200.329(c)(1) states that non-Federal entities must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Per the City’s Ohio Department of Development Water and Wastewater Infrastructure Program Grant Agreement, program reports must be submitted by close of business, on the second Friday at the end of each quarter. Program reports must include the following information: a. Narrative summary of use of funds during the reporting period b. Narrative describing promoting equitable outcomes. Describe efforts used to promote equitable outcomes, including how projects were implemented with equity in mind. c. Narrative describing community engagement d. Labor Practices: Describe workforce practices on projects implemented. How is the project using strong labor standards to promote effective and efficient delivery of high quality infrastructure. e. Project Construction Start Date (if applicable) f. Project Operations date g. National Pollutant Discharge Elimination System (NPDES) Permit Number (if applicable) h. Public Water System (PWS) ID Number (if applicable) i. Information on Matching funds utilized during the reporting period (i.e., source, amount and uses) The City did not have proper internal controls in place to ensure the timely submission of the quarterly performance reports related to the Galalina & Harbor Area Sanitary Sewer Rehabilitation. We noted that the City did not file the first of the third quarterly reports as required by their grant agreement.Failure to have the proper controls in place to ensure the timely submission of the quarterly performance reports could result in the Treasury taking action against the City for failure to comply with programmatic requirements. The City should implement and have controls in place to ensure the quarterly performance reports are filed by the required due dates.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.329, recipients must submit performance reports as required by the Federal awarding agency and ensure such reports are accurate, complete, and submitted timely. Additionally, 2 CFR 200.303 requires the entity to establish and maintain effective internal controls over Federal awards, including controls that provide reasonable assurance that reporting requirements are met and that documentation is retained to support compliance. Condition: During testing of reporting, we noted the following: - Management stated that required reviews and approvals of performance reports were conducted in person, but the organization does not maintain documentation or an audit trail to evidence these reviews. While documentation was available for quarterly performance reports, 2 of 2 annual performance reports and 6 of 21 monthly performance reports tested lacked evidence of review and approval. - Additionally, 6 of 10 performance reports selected for testing were not submitted/uploaded timely in accordance with grantor requirements. Questioned costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed. Cause: The Organization has not established formalized policies and procedures governing the preparation, review, and timely submission of performance reports. As a result, responsibility for monitoring reporting deadlines and performing supervisory review was informal and not consistently documented. Effect: Failure to submit required performance reports timely increases the risk of noncompliance with federal award requirements and may result in adverse actions by the federal awarding agency, including delayed reimbursements or additional monitoring. Additionally, the lack of a documented review process increases the risk that performance reports may be incomplete, inaccurate, or not aligned with program requirements. Repeat finding: No Recommendation: We recommend the Organization develop and implement formal policies and procedures to ensure required performance reports are prepared, reviewed, and submitted in a timely manner. Such procedures should include clearly defined roles and responsibilities, tracking of reporting deadlines, and documented evidence of supervisory review and approval prior to submission. Views of responsible officials: There is no disagreement with the audit finding.
Noncompliance and Significant Deficiency 2 C.F.R. § 1000.10 gives regulatory effect to the U.S. Department of the Treasury for 2 C.F.R. § 200.329(c)(1), which requires non-Federal entities to submit performance reports at the intervals required by the Federal awarding agency. Additionally, the U.S. Department of the Treasury's Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Guidance on Recipient Compliance and Reporting Responsibilities requires eligible recipients to submit Project and Expenditure Reports on a quarterly basis, including information regarding project obligations and expenditures. The County did not have adequate procedures in place to ensure compliance with SLFRF reporting requirements. As a result, the required Project and Expenditure Reports were not submitted for three of the four quarters (75%) during the year ended December 31, 2024. Failure to submit required reports resulted in noncompliance with federal grant requirements and limited the U.S. Department of the Treasury's ability to monitor the County's use of SLFRF funds. The County should review applicable grant requirements and establish procedures to ensure all required reports are prepared and submitted by the prescribed deadlines. The County should also ensure reported information agrees to the County's accounting records.
2 CFR § 1000.10 provides that, except for the deviations set forth elsewhere in this Part, the Department of Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards set forth at 2 CFR Part 200. CFR § 200.302(a) states, in part, the non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions ; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award.. 2 CFR § 200.302(b)(2) states, in part, the financial management system of each non-Federal entity must provide for accurate, current, and complete disclosures of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. 2 CFR § 200.329(c)(1) further states, in part, the recipient or subrecipient must submit performance reports as required by the Federal award. Intervals must be no less frequent than annually nor more frequent than quarterly except if specific conditions are applied set forth in § 200.208. Additionally, the Ohio Department of Development (ODOD) Water and Wastewater Infrastructure Program Grant Agreement provides in Exhibit II that "Program reports must be submitted on a quarterly basis. Program reports must be submitted by close of business, on the second Friday at the end of each quarter.” Due to deficiencies in the City’s internal controls over reporting, the City did not submit quarterly program reports for any quarter in 2024. Failure to submit required quarterly program reports could result in the City not receiving the reimbursements that it is entitled to as well as adversely impact future grant awards. The City should implement internal controls to help ensure that reports are submitted by the required deadlines per reporting requirements.
Coronavirus State and Local Fiscal Recovery Funds – Assistance Lising No. 21.027 U.S Department of Treasury Oklahoma State Department of Health Criteria or Specific Requirement – Reporting (2 CFR 200.329) Condition – The Organization’s internal controls over compliance were not able to ensure progress reporting required to be submitted to the pass-through entity was completed timely. Cause – The Organization does not have internal controls over compliance in place to ensure all grant reporting requirements are satisfied timely. Effect or potential effect – The Organization did not submit the required quarterly progress reports in a timely manner. Questioned costs – None Context – The Organization is required to submit quarterly progress reports to the pass-through entity in a timely manner. Identification as a repeat finding, if applicable – No. Recommendation – The Organization should consider implementing a grant reporting calendar for all grants with reporting requirements.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
Coronavirus State and Local Fiscal Recovery Funds – Assistance Lising No. 21.027 U.S Department of Treasury Oklahoma State Department of Health Criteria or Specific Requirement – Reporting (2 CFR 200.329) Condition – The Organization’s internal controls over compliance were not able to ensure progress reporting required to be submitted to the pass-through entity was completed timely. Cause – The Organization does not have internal controls over compliance in place to ensure all grant reporting requirements are satisfied timely. Effect or potential effect – The Organization did not submit the required quarterly progress reports in a timely manner. Questioned costs – None Context – The Organization is required to submit quarterly progress reports to the pass-through entity in a timely manner. Identification as a repeat finding, if applicable – No. Recommendation – The Organization should consider implementing a grant reporting calendar for all grants with reporting requirements.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 005 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.328 and 2 CFR 200.329)) requires non-federal entities to submit performance and financial reports as required by the pass-through entity award and to ensure that the data accumulated and summarized is in accordance with the required criteria and methodology. Effective internal controls should ensure grant closeout reports are supported by documentation of expenditures that have been incurred. Additionally, grant agreements requiring grant closeout reports should be reconciled to the accounting records. Condition: The County did not retain supporting documentation for closeout performance reports. Accounting records supporting the SEFA did not reconcile to the certified cost reported in the closeout financial reports. There were also instances where federal reimbursements did not align with project accounting code records. Questioned Costs: None Context: 2 of 3 closeout performance reports tested lacked supporting documentation. 2 of 3 closeout financial reports tested did not reconcile to the accounting records supporting the SEFA or to the project accounting code records. Cause: Supporting documentation for closeout performance reports was not retained. Additionally, adjustments made to the project accounting records after submission of the closeout financial reports and reconciliations resulted in discrepancies between reported and actual cost. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 005 Reporting (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-007. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to grant closeout reports and that supporting documentation is retained. A detailed, documented review of all reports should be conducted by someone other than the preparer to ensure completeness and accuracy. No financial activity should be recorded to the project accounting records after grant closeout reports are completed. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Treasury Federal Program Name: COVID 19-Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP4201; FY24 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit performance reports required by Federal award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the reported projects and expenditures accurately reflect what is reported in the expenditure detail and amounts obligated should reflect total procurement amounts awarded. Condition: While the correct expenditures were reported on the schedule of expenditures of federal awards, the performance report filed during the year did not accurately report project details. Current period expenditures and obligations should have reported amounts expended and procurement amounts awarded during the reporting period and cumulative expenditure and obligations should have reported amounts expended and procurement amounts awarded from the start of the grant through the end of the reporting period. Questioned Costs: None Context: 1 of 1 tested for reporting documentation. Cause: Total current period expenditures and obligations and total accumulated expenditures and obligations were not reconciled to the expenditure detail and procurement award detail. Prior period performance report overstated current period expenditures and obligations. These errors were corrected through current period performance report tested, which causes current period expenditures and obligations to be understated. Effect: Cost could be disallowed as UGG was not followed. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-005. Recommendation: We recommend the County perform a reconciliation of the project details reported to the expenditure detail and procurement amounts awarded detail used to support the SEFA, and these reconciliations be reviewed, to ensure accuracy and completeness of the reporting. Views of Responsible Officials: There is no disagreement with the audit finding.
Program Affected Assistance Listing 93.566 Department of Health and Human Services - Direct Award Refugee and Entrant Assistance State/Replacement Designee Administered Programs Award Year October 1, 2023 through September 30, 2025 Criteria 2 CFR §200.329(a) specifies that "The recipient and subrecipient must monitor their activities under Federal awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient and subrecipient must cover each program, function, or activity." Condition and Context Management was notified by program staff that invoices for services rendered during the last quarter of the fiscal year were pending approval and were therefore not captured in the year end accrual. An internal control deficiency was identified related to monitoring of the subrecipient's programmatic activity which are only performed sporadically, and as such, review of such activity at year end was not completed in a timely manner. Cause and Effect The condition identified was caused by infrequent and informal review of program-related subrecipient costs, which were not reconciled as this process was not occurring on a regularly scheduled basis. This resulted in an understatement of program-related subrecipient expenses of $247,119. The schedule of expenditures of federal awards has been adjusted to include these expenses. Recommendation We recommend the Organization perform monthly reconciliations of programmatic accruals for its subrecipients and adjust general ledger accounts accordingly. Management's estimate should materially reflect the services rendered for which the Organization is responsible. Identification as a Repeat Finding, if Applicable Not applicable. Views of Responsible Officials and Planned Corrective Action Management agrees with the finding. See attached Corrective Action Plan.
Program Affected Assistance Listing 93.566 Department of Health and Human Services - Direct Award Refugee and Entrant Assistance State/Replacement Designee Administered Programs Award Year October 1, 2023 through September 30, 2025 Criteria 2 CFR §200.329(a) specifies that "The recipient and subrecipient must monitor their activities under Federal awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient and subrecipient must cover each program, function, or activity." Condition and Context Management was notified by program staff that invoices for services rendered during the last quarter of the fiscal year were pending approval and were therefore not captured in the year end accrual. An internal control deficiency was identified related to monitoring of the subrecipient's programmatic activity which are only performed sporadically, and as such, review of such activity at year end was not completed in a timely manner. Cause and Effect The condition identified was caused by infrequent and informal review of program-related subrecipient costs, which were not reconciled as this process was not occurring on a regularly scheduled basis. This resulted in an understatement of program-related subrecipient expenses of $247,119. The schedule of expenditures of federal awards has been adjusted to include these expenses. Recommendation We recommend the Organization perform monthly reconciliations of programmatic accruals for its subrecipients and adjust general ledger accounts accordingly. Management's estimate should materially reflect the services rendered for which the Organization is responsible. Identification as a Repeat Finding, if Applicable Not applicable. Views of Responsible Officials and Planned Corrective Action Management agrees with the finding. See attached Corrective Action Plan.
Program Affected Assistance Listing 93.566 Department of Health and Human Services - Direct Award Refugee and Entrant Assistance State/Replacement Designee Administered Programs Award Year October 1, 2023 through September 30, 2025 Criteria 2 CFR §200.329(a) specifies that "The recipient and subrecipient must monitor their activities under Federal awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient and subrecipient must cover each program, function, or activity." Condition and Context Management was notified by program staff that invoices for services rendered during the last quarter of the fiscal year were pending approval and were therefore not captured in the year end accrual. An internal control deficiency was identified related to monitoring of the subrecipient's programmatic activity which are only performed sporadically, and as such, review of such activity at year end was not completed in a timely manner. Cause and Effect The condition identified was caused by infrequent and informal review of program-related subrecipient costs, which were not reconciled as this process was not occurring on a regularly scheduled basis. This resulted in an understatement of program-related subrecipient expenses of $247,119. The schedule of expenditures of federal awards has been adjusted to include these expenses. Recommendation We recommend the Organization perform monthly reconciliations of programmatic accruals for its subrecipients and adjust general ledger accounts accordingly. Management's estimate should materially reflect the services rendered for which the Organization is responsible. Identification as a Repeat Finding, if Applicable Not applicable. Views of Responsible Officials and Planned Corrective Action Management agrees with the finding. See attached Corrective Action Plan.
Program Affected Assistance Listing 93.566 Department of Health and Human Services - Direct Award Refugee and Entrant Assistance State/Replacement Designee Administered Programs Award Year October 1, 2023 through September 30, 2025 Criteria 2 CFR §200.329(a) specifies that "The recipient and subrecipient must monitor their activities under Federal awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient and subrecipient must cover each program, function, or activity." Condition and Context Management was notified by program staff that invoices for services rendered during the last quarter of the fiscal year were pending approval and were therefore not captured in the year end accrual. An internal control deficiency was identified related to monitoring of the subrecipient's programmatic activity which are only performed sporadically, and as such, review of such activity at year end was not completed in a timely manner. Cause and Effect The condition identified was caused by infrequent and informal review of program-related subrecipient costs, which were not reconciled as this process was not occurring on a regularly scheduled basis. This resulted in an understatement of program-related subrecipient expenses of $247,119. The schedule of expenditures of federal awards has been adjusted to include these expenses. Recommendation We recommend the Organization perform monthly reconciliations of programmatic accruals for its subrecipients and adjust general ledger accounts accordingly. Management's estimate should materially reflect the services rendered for which the Organization is responsible. Identification as a Repeat Finding, if Applicable Not applicable. Views of Responsible Officials and Planned Corrective Action Management agrees with the finding. See attached Corrective Action Plan.
Reporting (Significant Deficiency and Noncompliance) Information on the federal program: U.S. Department of the Homeland Security, Assistance listing # 97.044 Assistance to Firefighters Criteria: CFR 200.329c requires that reports submitted quarterly or semiannually must be filed no later than 30 calendar days after the reporting period. Condition: We examined the two semiannual Programmatic Performance reports and the semiannual SF425 financial report required to be submitted during the City’s fiscal year. Two of these were not filed within 30 days of specified reporting period as required. Cause: The reports not submitted timely were due July 30. The City’s controls around reporting focus on fiscal and calendar year end. The calendar-year semiannual reporting period is not in the City’s normal reporting schedule and therefore was not addressed through the controls in place. Both reports were filed within 16 days of the due date. Effect: The City did not timely fulfill all the related reporting requirements. Repeat Finding: Yes. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures surrounding grant reporting to include (at inception of each award) documentation of a schedule of reporting requirements, review, and approvals to ensure compliance and documentation of that compliance is retained to support applicable requirements. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan included at the end of the report.
2024-002 U.S. Department of Treasury, Federal Financial Assistance Listing #21.027, COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Matching, Level of Effort and Earmarking; Reporting Significant Deficiency in Internal Control over Compliance Criteria: Recipients of CSLFRF can calculate lost revenue for the years 2020, 2021, 2022, and 2023 based on the formula provided in the 2022 Final Rule to determine the amount of CSLFRF funds that can be used for the “provision of government services”. In calculating revenue loss, recipients can choose whether to use calendar or fiscal year dates but must be consistent throughout the period of performance. If calculating revenue loss, recipients must provide auditors with evidence supporting their revenue loss calculation. Non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly, except in unusual circumstances, using a form or format authorized by OMB (2 CFR section 200.329). Condition: During the testing over Earmarking, it was noted the County was not able to completely support the amounts used in the calculation. Further, there was no evidence of review of the calculation. Cause: The County’s controls were not sufficient to ensure someone other than the preparer of the revenue loss calculation reviewed the calculation prior to its submission on the County’s quarterly reports. Effect: The revenue loss number calculated by the County was incorrect. This incorrect number was reported to the Treasury as part of the County’s quarterly reporting requirement. Questioned Costs: None reported. Context/Sampling: Sampling was not used for the Earmarking compliance test as there was only 1 revenue loss calculation. A statistical sample of 2 reports were selected for testing out of a total population of 4. Repeat Finding from Prior Year(s): No Recommendation: Management should review the revenue loss calculation to ensure it is appropriately supported by underlying documentation. For all future reports submitted to the Treasury, the recalculated revenue loss amount should be used. Views of Responsible Officials: The County agrees with the auditor’s findings
Finding 2024-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Program Name: Multiple federal programs Criteria 1. The code of federal regulations – 2 CFR 200.302 Financial management requires that: (a) Each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State’s funds. All recipient and subrecipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) The recipient’s and subrecipient’s financial management system must provide for the following: (1) Identification of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number, year the Federal award was issued, and name of the Federal agency or pass-through entity. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in § 200.328 and § 200.329. When a Federal agency or pass-through entity requires reporting on an accrual basis from a recipient or subrecipient that maintains its records other than on an accrual basis, the recipient or subrecipient must not be required to establish an accrual accounting system. This recipient or subrecipient may develop accrual data for its reports based on an analysis of the documentation on hand. 2. The code of federal regulations – 2 CFR 200.303 Internal controls requires that recipients and subrecipients must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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 award. (c) Evaluate and monitor the recipient’s or subrecipient’s compliance with statutes, regulations, and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified. Condition The following exceptions to the criteria were observed during the performance of the audit procedures: 1. After the completion of internal review and approval process that Amtrak has established for SEFA preparation and review, we have received multiple updated versions of the schedule with changes to FY24 expenditure amounts for three Assistance Listings included on the SEFA. Total expenditures increased by $80.2 million from version 1 to the final version received. 2. The starting point of the SEFA preparation for the current year was not the audited FY23 SEFA submitted to Federal Audit Clearinghouse, as we have identified that Amtrak subsequently made changes to the FY23 internal SEFA document without reconciling the changes to the audited FY23 SEFA, which resulted in the total cumulative expenditures as of 9/30/2023 to be updated and as such impacting the FY24 expenditures for the respective federal programs. One of the adjustments related to the Hudson Yards Concrete Casing project (HYCC-3) which initially incorrectly recorded $25.0 million of prepaid expenditures. 3. As Assistance Listing #20.314 has been obligated as of 9/27/2024, Amtrak has recorded expenditures related to the HYCC-3 project under this program for the established pre-award period, which dated from January 30, 2023 as part of the FY24 expenditures. Previously, a portion of the total expenditures was included within the FY23 SEFA under Assistance Listing #20.315, for the total amount of $15.6 million. This amount was not adjusted out of the cumulative expenditures for Assistance Listing #20.315 until 2025. Consequently, these expenditures were listed both within the FY23 SEFA under Assistance Listing #20.315 and under the FY24 SEFA as Assistance Listing #20.314 expenditures. 4. As part of SEFA preparation as it relates to allocation of operating expenditures across multiple funding sources, certain projects were incorrectly mapped to annual grants funding source, which resulted in approximately $0.3 million of operating expenses to be included within Assistance Listing #20.315 that were also reported under Assistance Listing #97.075. Cause Amtrak’s control procedures in place as it relates to the preparation of the SEFA were not operating in a manner that would timely identify the conditions noted. Additionally, Amtrak’s controls around allocation of federal funding to project codes were not designed in a manner that would timely identify the conditions noted. In reviewing management’s controls around the SEFA preparation, the design of key controls identified by management does not include an overarching review of the SEFA and reconciliation of what’s been reported on the SEFA from individual projects’ standpoint when such projects have multiple assistance listings as funding sources. We also noted that there was not a specific control that ensures timely updates of Work Breakdown Structure (WBS) funding assignments and allocations when there is a change such as a new grant agreement signed. Effect Amtrak’s control procedures in place as it relates to the preparation of the SEFA were not designed in such a manner that would timely identify the conditions noted, which resulted in several versions of the SEFA that were erroneous and inclusion of expenditures that were double counted within the SEFA. This puts Amtrak at greater risk of non-compliance with its grant agreements with respect to questioned costs and an inaccurate SEFA. Questioned Costs None. Context The SEFA, as originally provided, had exceptions as described in the Condition section above noted for matters 1 and 2 in the Criteria section above, indicating that certain internal controls were not functioning as designed and others were not designed effectively. Identification as a Repeat Finding Not a repeat finding. Recommendation We recommend Amtrak to strengthen the SEFA oversight process to ensure appropriate preparation and review of the SEFA to validate its accuracy, including reconciliation with prior year audited SEFA. This should include having one reviewer take overall responsibility for the completeness and accuracy of the final submitted SEFA. This robust review process should include appropriate procedures to confirm accuracy of the SEFA, which may include a protocol where representatives from various groups (both discretionary and non-discretionary federal programs) work collaboratively to review the SEFA and underlying details of expenditures, to ensure all the adjustments have been properly reflected as well as any projects that might have multiple fund sources are identified timely and reviewed for appropriate inclusion within the SEFA. Additionally, Amtrak should establish a process where any modifications of WBS funding assignments and allocations are updated in a timely manner. Views of Responsible Officials Amtrak recognizes the need to improve the preparation and review of the SEFA. The company has documented the steps for preparing and reviewing the SEFA within its process narrative. The company will update the narrative to address the preparation and review issues that led to the multiple versions of the SEFA being provided during the audit. The company will review and update the Grants Management Compliance Narrative and controls to improve timing of updates for modifications of WBS funding assignments. The company is in the process of updating the SEFA preparation documentation for FY2025, which will be used at the end of the year. The review procedures and controls are being enhanced to include a checklist to improve the review.
Finding 2024-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Program Name: Multiple federal programs Criteria 1. The code of federal regulations – 2 CFR 200.302 Financial management requires that: (a) Each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State’s funds. All recipient and subrecipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) The recipient’s and subrecipient’s financial management system must provide for the following: (1) Identification of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number, year the Federal award was issued, and name of the Federal agency or pass-through entity. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in § 200.328 and § 200.329. When a Federal agency or pass-through entity requires reporting on an accrual basis from a recipient or subrecipient that maintains its records other than on an accrual basis, the recipient or subrecipient must not be required to establish an accrual accounting system. This recipient or subrecipient may develop accrual data for its reports based on an analysis of the documentation on hand. 2. The code of federal regulations – 2 CFR 200.303 Internal controls requires that recipients and subrecipients must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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 award. (c) Evaluate and monitor the recipient’s or subrecipient’s compliance with statutes, regulations, and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified. Condition The following exceptions to the criteria were observed during the performance of the audit procedures: 1. After the completion of internal review and approval process that Amtrak has established for SEFA preparation and review, we have received multiple updated versions of the schedule with changes to FY24 expenditure amounts for three Assistance Listings included on the SEFA. Total expenditures increased by $80.2 million from version 1 to the final version received. 2. The starting point of the SEFA preparation for the current year was not the audited FY23 SEFA submitted to Federal Audit Clearinghouse, as we have identified that Amtrak subsequently made changes to the FY23 internal SEFA document without reconciling the changes to the audited FY23 SEFA, which resulted in the total cumulative expenditures as of 9/30/2023 to be updated and as such impacting the FY24 expenditures for the respective federal programs. One of the adjustments related to the Hudson Yards Concrete Casing project (HYCC-3) which initially incorrectly recorded $25.0 million of prepaid expenditures. 3. As Assistance Listing #20.314 has been obligated as of 9/27/2024, Amtrak has recorded expenditures related to the HYCC-3 project under this program for the established pre-award period, which dated from January 30, 2023 as part of the FY24 expenditures. Previously, a portion of the total expenditures was included within the FY23 SEFA under Assistance Listing #20.315, for the total amount of $15.6 million. This amount was not adjusted out of the cumulative expenditures for Assistance Listing #20.315 until 2025. Consequently, these expenditures were listed both within the FY23 SEFA under Assistance Listing #20.315 and under the FY24 SEFA as Assistance Listing #20.314 expenditures. 4. As part of SEFA preparation as it relates to allocation of operating expenditures across multiple funding sources, certain projects were incorrectly mapped to annual grants funding source, which resulted in approximately $0.3 million of operating expenses to be included within Assistance Listing #20.315 that were also reported under Assistance Listing #97.075. Cause Amtrak’s control procedures in place as it relates to the preparation of the SEFA were not operating in a manner that would timely identify the conditions noted. Additionally, Amtrak’s controls around allocation of federal funding to project codes were not designed in a manner that would timely identify the conditions noted. In reviewing management’s controls around the SEFA preparation, the design of key controls identified by management does not include an overarching review of the SEFA and reconciliation of what’s been reported on the SEFA from individual projects’ standpoint when such projects have multiple assistance listings as funding sources. We also noted that there was not a specific control that ensures timely updates of Work Breakdown Structure (WBS) funding assignments and allocations when there is a change such as a new grant agreement signed. Effect Amtrak’s control procedures in place as it relates to the preparation of the SEFA were not designed in such a manner that would timely identify the conditions noted, which resulted in several versions of the SEFA that were erroneous and inclusion of expenditures that were double counted within the SEFA. This puts Amtrak at greater risk of non-compliance with its grant agreements with respect to questioned costs and an inaccurate SEFA. Questioned Costs None. Context The SEFA, as originally provided, had exceptions as described in the Condition section above noted for matters 1 and 2 in the Criteria section above, indicating that certain internal controls were not functioning as designed and others were not designed effectively. Identification as a Repeat Finding Not a repeat finding. Recommendation We recommend Amtrak to strengthen the SEFA oversight process to ensure appropriate preparation and review of the SEFA to validate its accuracy, including reconciliation with prior year audited SEFA. This should include having one reviewer take overall responsibility for the completeness and accuracy of the final submitted SEFA. This robust review process should include appropriate procedures to confirm accuracy of the SEFA, which may include a protocol where representatives from various groups (both discretionary and non-discretionary federal programs) work collaboratively to review the SEFA and underlying details of expenditures, to ensure all the adjustments have been properly reflected as well as any projects that might have multiple fund sources are identified timely and reviewed for appropriate inclusion within the SEFA. Additionally, Amtrak should establish a process where any modifications of WBS funding assignments and allocations are updated in a timely manner. Views of Responsible Officials Amtrak recognizes the need to improve the preparation and review of the SEFA. The company has documented the steps for preparing and reviewing the SEFA within its process narrative. The company will update the narrative to address the preparation and review issues that led to the multiple versions of the SEFA being provided during the audit. The company will review and update the Grants Management Compliance Narrative and controls to improve timing of updates for modifications of WBS funding assignments. The company is in the process of updating the SEFA preparation documentation for FY2025, which will be used at the end of the year. The review procedures and controls are being enhanced to include a checklist to improve the review.
Program Information: U.S. Department of Commerce NOAA Hatchery Genetic Mgmt – Assistance Listing #11.437 Award Number: NA18NMF4370324 Award Period: 7/01/2018 – 6/30/2024 Criteria: Reporting requirements are contained in the following: Monitoring and reporting program performance, 2 CFR Section 200.329. • Per the award documents, the grantee shall prepare and provide progress reports to Pacific States Marine Fisheries Commission (PSMFC). These run January to June and July to December and are due 15 days after each period. Per 2 CFR § 200.303 Internal controls, the non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the Federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: NWIFC could not provide support showing review and approval of the progress reports prior to submitting them to PSMFC. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: It appears the policies and procedures for reporting were not followed. Effect: Failing to comply with the grant award requirements, the program may be subject to higher risk status and a decreased amount of funding. Questioned Costs: Not applicable – The condition relates to the lack of review and approval of the required reports before submitting to the funding agency, which does not directly impact the allowability or support for costs charged to the program. No costs are being questioned as a result. Repeat Finding: No. Recommendation: We recommend that the NWIFC adhere to program policies and procedures as documented and supporting documentation is kept available for review. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Non-Compliance - Reporting Criteria: 2 CFR section 200.329 Requires certain program performance reports to be filed on a timely basis. Condition: Insufficient controls over performance reporting resulted in program performance reports not being timely filed by the Organization. Context/Cause: The Organization receives federal funding through a passthrough agency, the Alabama Department of Mental Health. In accordance with the contract with the Alabama Department of Mental Health, certain performance reports are required to be filed on a quarterly basis by the 10th of the month following the quarter end. Effects: Due to the resignation of the personnel responsible for filing the required reports, and management’s lack of control over the reporting process, the reports were not timely filed. Recommendation: We recommend that management and the board oversee the reporting function so that issues arising with personnel do not prevent the timely filing of the reports. Auditee’s Response: The Organization will cross train staff and create a schedule for the filing of reports on a timely basis and will monitor this more closely in future.
Non-Compliance - Reporting Criteria: 2 CFR section 200.329 Requires certain program performance reports to be filed on a timely basis. Condition: Insufficient controls over performance reporting resulted in program performance reports not being timely filed by the Organization. Context/Cause: The Organization receives federal funding through a passthrough agency, the Alabama Department of Mental Health. In accordance with the contract with the Alabama Department of Mental Health, certain performance reports are required to be filed on a quarterly basis by the 10th of the month following the quarter end. Effects: Due to the resignation of the personnel responsible for filing the required reports, and management’s lack of control over the reporting process, the reports were not timely filed. Recommendation: We recommend that management and the board oversee the reporting function so that issues arising with personnel do not prevent the timely filing of the reports. Auditee’s Response: The Organization will cross train staff and create a schedule for the filing of reports on a timely basis and will monitor this more closely in future.
Non-Compliance - Reporting Criteria: 2 CFR section 200.329 Requires certain program performance reports to be filed on a timely basis. Condition: Insufficient controls over performance reporting resulted in program performance reports not being timely filed by the Organization. Context/Cause: The Organization receives federal funding through a passthrough agency, the Alabama Department of Mental Health. In accordance with the contract with the Alabama Department of Mental Health, certain performance reports are required to be filed on a quarterly basis by the 10th of the month following the quarter end. Effects: Due to the resignation of the personnel responsible for filing the required reports, and management’s lack of control over the reporting process, the reports were not timely filed. Recommendation: We recommend that management and the board oversee the reporting function so that issues arising with personnel do not prevent the timely filing of the reports. Auditee’s Response: The Organization will cross train staff and create a schedule for the filing of reports on a timely basis and will monitor this more closely in future.
Program Affected Assistance Listing 93.566 Department of Health and Human Services - Direct Award Refugee and Entrant Assistance State/Replacement Designee Administered Programs Award Year October 1, 2023 through September 30, 2025 Criteria 2 CFR §200.329(a) specifies that "The recipient and subrecipient must monitor their activities under Federal awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient and subrecipient must cover each program, function, or activity." Condition and Context Management was notified by program staff that invoices for services rendered during the last quarter of the fiscal year were pending approval and were therefore not captured in the year end accrual. An internal control deficiency was identified related to monitoring of the subrecipient's programmatic activity which are only performed sporadically, and as such, review of such activity at year end was not completed in a timely manner. Cause and Effect The condition identified was caused by infrequent and informal review of program-related subrecipient costs, which were not reconciled as this process was not occurring on a regularly scheduled basis. This resulted in an understatement of program-related subrecipient expenses of $247,119. The schedule of expenditures of federal awards has been adjusted to include these expenses. Recommendation We recommend the Organization perform monthly reconciliations of programmatic accruals for its subrecipients and adjust general ledger accounts accordingly. Management's estimate should materially reflect the services rendered for which the Organization is responsible. Identification as a Repeat Finding, if Applicable Not applicable. Views of Responsible Officials and Planned Corrective Action Management agrees with the finding. See attached Corrective Action Plan.
Program Affected Assistance Listing 93.566 Department of Health and Human Services - Direct Award Refugee and Entrant Assistance State/Replacement Designee Administered Programs Award Year October 1, 2023 through September 30, 2025 Criteria 2 CFR §200.329(a) specifies that "The recipient and subrecipient must monitor their activities under Federal awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient and subrecipient must cover each program, function, or activity." Condition and Context Management was notified by program staff that invoices for services rendered during the last quarter of the fiscal year were pending approval and were therefore not captured in the year end accrual. An internal control deficiency was identified related to monitoring of the subrecipient's programmatic activity which are only performed sporadically, and as such, review of such activity at year end was not completed in a timely manner. Cause and Effect The condition identified was caused by infrequent and informal review of program-related subrecipient costs, which were not reconciled as this process was not occurring on a regularly scheduled basis. This resulted in an understatement of program-related subrecipient expenses of $247,119. The schedule of expenditures of federal awards has been adjusted to include these expenses. Recommendation We recommend the Organization perform monthly reconciliations of programmatic accruals for its subrecipients and adjust general ledger accounts accordingly. Management's estimate should materially reflect the services rendered for which the Organization is responsible. Identification as a Repeat Finding, if Applicable Not applicable. Views of Responsible Officials and Planned Corrective Action Management agrees with the finding. See attached Corrective Action Plan.
Program Affected Assistance Listing 93.566 Department of Health and Human Services - Direct Award Refugee and Entrant Assistance State/Replacement Designee Administered Programs Award Year October 1, 2023 through September 30, 2025 Criteria 2 CFR §200.329(a) specifies that "The recipient and subrecipient must monitor their activities under Federal awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient and subrecipient must cover each program, function, or activity." Condition and Context Management was notified by program staff that invoices for services rendered during the last quarter of the fiscal year were pending approval and were therefore not captured in the year end accrual. An internal control deficiency was identified related to monitoring of the subrecipient's programmatic activity which are only performed sporadically, and as such, review of such activity at year end was not completed in a timely manner. Cause and Effect The condition identified was caused by infrequent and informal review of program-related subrecipient costs, which were not reconciled as this process was not occurring on a regularly scheduled basis. This resulted in an understatement of program-related subrecipient expenses of $247,119. The schedule of expenditures of federal awards has been adjusted to include these expenses. Recommendation We recommend the Organization perform monthly reconciliations of programmatic accruals for its subrecipients and adjust general ledger accounts accordingly. Management's estimate should materially reflect the services rendered for which the Organization is responsible. Identification as a Repeat Finding, if Applicable Not applicable. Views of Responsible Officials and Planned Corrective Action Management agrees with the finding. See attached Corrective Action Plan.
Program Affected Assistance Listing 93.566 Department of Health and Human Services - Direct Award Refugee and Entrant Assistance State/Replacement Designee Administered Programs Award Year October 1, 2023 through September 30, 2025 Criteria 2 CFR §200.329(a) specifies that "The recipient and subrecipient must monitor their activities under Federal awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient and subrecipient must cover each program, function, or activity." Condition and Context Management was notified by program staff that invoices for services rendered during the last quarter of the fiscal year were pending approval and were therefore not captured in the year end accrual. An internal control deficiency was identified related to monitoring of the subrecipient's programmatic activity which are only performed sporadically, and as such, review of such activity at year end was not completed in a timely manner. Cause and Effect The condition identified was caused by infrequent and informal review of program-related subrecipient costs, which were not reconciled as this process was not occurring on a regularly scheduled basis. This resulted in an understatement of program-related subrecipient expenses of $247,119. The schedule of expenditures of federal awards has been adjusted to include these expenses. Recommendation We recommend the Organization perform monthly reconciliations of programmatic accruals for its subrecipients and adjust general ledger accounts accordingly. Management's estimate should materially reflect the services rendered for which the Organization is responsible. Identification as a Repeat Finding, if Applicable Not applicable. Views of Responsible Officials and Planned Corrective Action Management agrees with the finding. See attached Corrective Action Plan.
Reporting (Significant Deficiency and Noncompliance) Information on the federal program: U.S. Department of the Homeland Security, Assistance listing # 97.044 Assistance to Firefighters Criteria: CFR 200.329c requires that reports submitted quarterly or semiannually must be filed no later than 30 calendar days after the reporting period. Condition: We examined the two semiannual Programmatic Performance reports and the semiannual SF425 financial report required to be submitted during the City’s fiscal year. Two of these were not filed within 30 days of specified reporting period as required. Cause: The reports not submitted timely were due July 30. The City’s controls around reporting focus on fiscal and calendar year end. The calendar-year semiannual reporting period is not in the City’s normal reporting schedule and therefore was not addressed through the controls in place. Both reports were filed within 16 days of the due date. Effect: The City did not timely fulfill all the related reporting requirements. Repeat Finding: Yes. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures surrounding grant reporting to include (at inception of each award) documentation of a schedule of reporting requirements, review, and approvals to ensure compliance and documentation of that compliance is retained to support applicable requirements. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan included at the end of the report.
2024-002 U.S. Department of Treasury, Federal Financial Assistance Listing #21.027, COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Matching, Level of Effort and Earmarking; Reporting Significant Deficiency in Internal Control over Compliance Criteria: Recipients of CSLFRF can calculate lost revenue for the years 2020, 2021, 2022, and 2023 based on the formula provided in the 2022 Final Rule to determine the amount of CSLFRF funds that can be used for the “provision of government services”. In calculating revenue loss, recipients can choose whether to use calendar or fiscal year dates but must be consistent throughout the period of performance. If calculating revenue loss, recipients must provide auditors with evidence supporting their revenue loss calculation. Non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly, except in unusual circumstances, using a form or format authorized by OMB (2 CFR section 200.329). Condition: During the testing over Earmarking, it was noted the County was not able to completely support the amounts used in the calculation. Further, there was no evidence of review of the calculation. Cause: The County’s controls were not sufficient to ensure someone other than the preparer of the revenue loss calculation reviewed the calculation prior to its submission on the County’s quarterly reports. Effect: The revenue loss number calculated by the County was incorrect. This incorrect number was reported to the Treasury as part of the County’s quarterly reporting requirement. Questioned Costs: None reported. Context/Sampling: Sampling was not used for the Earmarking compliance test as there was only 1 revenue loss calculation. A statistical sample of 2 reports were selected for testing out of a total population of 4. Repeat Finding from Prior Year(s): No Recommendation: Management should review the revenue loss calculation to ensure it is appropriately supported by underlying documentation. For all future reports submitted to the Treasury, the recalculated revenue loss amount should be used. Views of Responsible Officials: The County agrees with the auditor’s findings
Finding 2024-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Program Name: Multiple federal programs Criteria 1. The code of federal regulations – 2 CFR 200.302 Financial management requires that: (a) Each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State’s funds. All recipient and subrecipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) The recipient’s and subrecipient’s financial management system must provide for the following: (1) Identification of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number, year the Federal award was issued, and name of the Federal agency or pass-through entity. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in § 200.328 and § 200.329. When a Federal agency or pass-through entity requires reporting on an accrual basis from a recipient or subrecipient that maintains its records other than on an accrual basis, the recipient or subrecipient must not be required to establish an accrual accounting system. This recipient or subrecipient may develop accrual data for its reports based on an analysis of the documentation on hand. 2. The code of federal regulations – 2 CFR 200.303 Internal controls requires that recipients and subrecipients must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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 award. (c) Evaluate and monitor the recipient’s or subrecipient’s compliance with statutes, regulations, and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified. Condition The following exceptions to the criteria were observed during the performance of the audit procedures: 1. After the completion of internal review and approval process that Amtrak has established for SEFA preparation and review, we have received multiple updated versions of the schedule with changes to FY24 expenditure amounts for three Assistance Listings included on the SEFA. Total expenditures increased by $80.2 million from version 1 to the final version received. 2. The starting point of the SEFA preparation for the current year was not the audited FY23 SEFA submitted to Federal Audit Clearinghouse, as we have identified that Amtrak subsequently made changes to the FY23 internal SEFA document without reconciling the changes to the audited FY23 SEFA, which resulted in the total cumulative expenditures as of 9/30/2023 to be updated and as such impacting the FY24 expenditures for the respective federal programs. One of the adjustments related to the Hudson Yards Concrete Casing project (HYCC-3) which initially incorrectly recorded $25.0 million of prepaid expenditures. 3. As Assistance Listing #20.314 has been obligated as of 9/27/2024, Amtrak has recorded expenditures related to the HYCC-3 project under this program for the established pre-award period, which dated from January 30, 2023 as part of the FY24 expenditures. Previously, a portion of the total expenditures was included within the FY23 SEFA under Assistance Listing #20.315, for the total amount of $15.6 million. This amount was not adjusted out of the cumulative expenditures for Assistance Listing #20.315 until 2025. Consequently, these expenditures were listed both within the FY23 SEFA under Assistance Listing #20.315 and under the FY24 SEFA as Assistance Listing #20.314 expenditures. 4. As part of SEFA preparation as it relates to allocation of operating expenditures across multiple funding sources, certain projects were incorrectly mapped to annual grants funding source, which resulted in approximately $0.3 million of operating expenses to be included within Assistance Listing #20.315 that were also reported under Assistance Listing #97.075. Cause Amtrak’s control procedures in place as it relates to the preparation of the SEFA were not operating in a manner that would timely identify the conditions noted. Additionally, Amtrak’s controls around allocation of federal funding to project codes were not designed in a manner that would timely identify the conditions noted. In reviewing management’s controls around the SEFA preparation, the design of key controls identified by management does not include an overarching review of the SEFA and reconciliation of what’s been reported on the SEFA from individual projects’ standpoint when such projects have multiple assistance listings as funding sources. We also noted that there was not a specific control that ensures timely updates of Work Breakdown Structure (WBS) funding assignments and allocations when there is a change such as a new grant agreement signed. Effect Amtrak’s control procedures in place as it relates to the preparation of the SEFA were not designed in such a manner that would timely identify the conditions noted, which resulted in several versions of the SEFA that were erroneous and inclusion of expenditures that were double counted within the SEFA. This puts Amtrak at greater risk of non-compliance with its grant agreements with respect to questioned costs and an inaccurate SEFA. Questioned Costs None. Context The SEFA, as originally provided, had exceptions as described in the Condition section above noted for matters 1 and 2 in the Criteria section above, indicating that certain internal controls were not functioning as designed and others were not designed effectively. Identification as a Repeat Finding Not a repeat finding. Recommendation We recommend Amtrak to strengthen the SEFA oversight process to ensure appropriate preparation and review of the SEFA to validate its accuracy, including reconciliation with prior year audited SEFA. This should include having one reviewer take overall responsibility for the completeness and accuracy of the final submitted SEFA. This robust review process should include appropriate procedures to confirm accuracy of the SEFA, which may include a protocol where representatives from various groups (both discretionary and non-discretionary federal programs) work collaboratively to review the SEFA and underlying details of expenditures, to ensure all the adjustments have been properly reflected as well as any projects that might have multiple fund sources are identified timely and reviewed for appropriate inclusion within the SEFA. Additionally, Amtrak should establish a process where any modifications of WBS funding assignments and allocations are updated in a timely manner. Views of Responsible Officials Amtrak recognizes the need to improve the preparation and review of the SEFA. The company has documented the steps for preparing and reviewing the SEFA within its process narrative. The company will update the narrative to address the preparation and review issues that led to the multiple versions of the SEFA being provided during the audit. The company will review and update the Grants Management Compliance Narrative and controls to improve timing of updates for modifications of WBS funding assignments. The company is in the process of updating the SEFA preparation documentation for FY2025, which will be used at the end of the year. The review procedures and controls are being enhanced to include a checklist to improve the review.
Finding 2024-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Program Name: Multiple federal programs Criteria 1. The code of federal regulations – 2 CFR 200.302 Financial management requires that: (a) Each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State’s funds. All recipient and subrecipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) The recipient’s and subrecipient’s financial management system must provide for the following: (1) Identification of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number, year the Federal award was issued, and name of the Federal agency or pass-through entity. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in § 200.328 and § 200.329. When a Federal agency or pass-through entity requires reporting on an accrual basis from a recipient or subrecipient that maintains its records other than on an accrual basis, the recipient or subrecipient must not be required to establish an accrual accounting system. This recipient or subrecipient may develop accrual data for its reports based on an analysis of the documentation on hand. 2. The code of federal regulations – 2 CFR 200.303 Internal controls requires that recipients and subrecipients must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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 award. (c) Evaluate and monitor the recipient’s or subrecipient’s compliance with statutes, regulations, and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified. Condition The following exceptions to the criteria were observed during the performance of the audit procedures: 1. After the completion of internal review and approval process that Amtrak has established for SEFA preparation and review, we have received multiple updated versions of the schedule with changes to FY24 expenditure amounts for three Assistance Listings included on the SEFA. Total expenditures increased by $80.2 million from version 1 to the final version received. 2. The starting point of the SEFA preparation for the current year was not the audited FY23 SEFA submitted to Federal Audit Clearinghouse, as we have identified that Amtrak subsequently made changes to the FY23 internal SEFA document without reconciling the changes to the audited FY23 SEFA, which resulted in the total cumulative expenditures as of 9/30/2023 to be updated and as such impacting the FY24 expenditures for the respective federal programs. One of the adjustments related to the Hudson Yards Concrete Casing project (HYCC-3) which initially incorrectly recorded $25.0 million of prepaid expenditures. 3. As Assistance Listing #20.314 has been obligated as of 9/27/2024, Amtrak has recorded expenditures related to the HYCC-3 project under this program for the established pre-award period, which dated from January 30, 2023 as part of the FY24 expenditures. Previously, a portion of the total expenditures was included within the FY23 SEFA under Assistance Listing #20.315, for the total amount of $15.6 million. This amount was not adjusted out of the cumulative expenditures for Assistance Listing #20.315 until 2025. Consequently, these expenditures were listed both within the FY23 SEFA under Assistance Listing #20.315 and under the FY24 SEFA as Assistance Listing #20.314 expenditures. 4. As part of SEFA preparation as it relates to allocation of operating expenditures across multiple funding sources, certain projects were incorrectly mapped to annual grants funding source, which resulted in approximately $0.3 million of operating expenses to be included within Assistance Listing #20.315 that were also reported under Assistance Listing #97.075. Cause Amtrak’s control procedures in place as it relates to the preparation of the SEFA were not operating in a manner that would timely identify the conditions noted. Additionally, Amtrak’s controls around allocation of federal funding to project codes were not designed in a manner that would timely identify the conditions noted. In reviewing management’s controls around the SEFA preparation, the design of key controls identified by management does not include an overarching review of the SEFA and reconciliation of what’s been reported on the SEFA from individual projects’ standpoint when such projects have multiple assistance listings as funding sources. We also noted that there was not a specific control that ensures timely updates of Work Breakdown Structure (WBS) funding assignments and allocations when there is a change such as a new grant agreement signed. Effect Amtrak’s control procedures in place as it relates to the preparation of the SEFA were not designed in such a manner that would timely identify the conditions noted, which resulted in several versions of the SEFA that were erroneous and inclusion of expenditures that were double counted within the SEFA. This puts Amtrak at greater risk of non-compliance with its grant agreements with respect to questioned costs and an inaccurate SEFA. Questioned Costs None. Context The SEFA, as originally provided, had exceptions as described in the Condition section above noted for matters 1 and 2 in the Criteria section above, indicating that certain internal controls were not functioning as designed and others were not designed effectively. Identification as a Repeat Finding Not a repeat finding. Recommendation We recommend Amtrak to strengthen the SEFA oversight process to ensure appropriate preparation and review of the SEFA to validate its accuracy, including reconciliation with prior year audited SEFA. This should include having one reviewer take overall responsibility for the completeness and accuracy of the final submitted SEFA. This robust review process should include appropriate procedures to confirm accuracy of the SEFA, which may include a protocol where representatives from various groups (both discretionary and non-discretionary federal programs) work collaboratively to review the SEFA and underlying details of expenditures, to ensure all the adjustments have been properly reflected as well as any projects that might have multiple fund sources are identified timely and reviewed for appropriate inclusion within the SEFA. Additionally, Amtrak should establish a process where any modifications of WBS funding assignments and allocations are updated in a timely manner. Views of Responsible Officials Amtrak recognizes the need to improve the preparation and review of the SEFA. The company has documented the steps for preparing and reviewing the SEFA within its process narrative. The company will update the narrative to address the preparation and review issues that led to the multiple versions of the SEFA being provided during the audit. The company will review and update the Grants Management Compliance Narrative and controls to improve timing of updates for modifications of WBS funding assignments. The company is in the process of updating the SEFA preparation documentation for FY2025, which will be used at the end of the year. The review procedures and controls are being enhanced to include a checklist to improve the review.
Program Information: U.S. Department of Commerce NOAA Hatchery Genetic Mgmt – Assistance Listing #11.437 Award Number: NA18NMF4370324 Award Period: 7/01/2018 – 6/30/2024 Criteria: Reporting requirements are contained in the following: Monitoring and reporting program performance, 2 CFR Section 200.329. • Per the award documents, the grantee shall prepare and provide progress reports to Pacific States Marine Fisheries Commission (PSMFC). These run January to June and July to December and are due 15 days after each period. Per 2 CFR § 200.303 Internal controls, the non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the Federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: NWIFC could not provide support showing review and approval of the progress reports prior to submitting them to PSMFC. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: It appears the policies and procedures for reporting were not followed. Effect: Failing to comply with the grant award requirements, the program may be subject to higher risk status and a decreased amount of funding. Questioned Costs: Not applicable – The condition relates to the lack of review and approval of the required reports before submitting to the funding agency, which does not directly impact the allowability or support for costs charged to the program. No costs are being questioned as a result. Repeat Finding: No. Recommendation: We recommend that the NWIFC adhere to program policies and procedures as documented and supporting documentation is kept available for review. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Non-Compliance - Reporting Criteria: 2 CFR section 200.329 Requires certain program performance reports to be filed on a timely basis. Condition: Insufficient controls over performance reporting resulted in program performance reports not being timely filed by the Organization. Context/Cause: The Organization receives federal funding through a passthrough agency, the Alabama Department of Mental Health. In accordance with the contract with the Alabama Department of Mental Health, certain performance reports are required to be filed on a quarterly basis by the 10th of the month following the quarter end. Effects: Due to the resignation of the personnel responsible for filing the required reports, and management’s lack of control over the reporting process, the reports were not timely filed. Recommendation: We recommend that management and the board oversee the reporting function so that issues arising with personnel do not prevent the timely filing of the reports. Auditee’s Response: The Organization will cross train staff and create a schedule for the filing of reports on a timely basis and will monitor this more closely in future.
Non-Compliance - Reporting Criteria: 2 CFR section 200.329 Requires certain program performance reports to be filed on a timely basis. Condition: Insufficient controls over performance reporting resulted in program performance reports not being timely filed by the Organization. Context/Cause: The Organization receives federal funding through a passthrough agency, the Alabama Department of Mental Health. In accordance with the contract with the Alabama Department of Mental Health, certain performance reports are required to be filed on a quarterly basis by the 10th of the month following the quarter end. Effects: Due to the resignation of the personnel responsible for filing the required reports, and management’s lack of control over the reporting process, the reports were not timely filed. Recommendation: We recommend that management and the board oversee the reporting function so that issues arising with personnel do not prevent the timely filing of the reports. Auditee’s Response: The Organization will cross train staff and create a schedule for the filing of reports on a timely basis and will monitor this more closely in future.