Finding Number: 2023-003 Assistance Listing Number and Title: Coronavirus State And Local Fiscal Recovery Funds AL # 21.027 Federal Award Identification Number: 2022ARCCB1134/ 2022-AR-LEP-937 Federal Agency: U.S. Department of Treasury Compliance Requirement: Reporting Pass-Through Entity: Ohio Department of Public Safety Repeat Finding from Prior Audit? No Noncompliance and Material Weakness 2 CFR § 1000.10 gives regulatory effect to Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200 for the Department of Treasury. 2 CFR 200.329 provides the recipient and subrecipient are responsible for the oversight of the Federal award. The recipient and subrecipient must monitor their activities under Federal awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient and subrecipient must cover each program, function, or activity. The Office of Criminal Justice Service Standard Subgrant Conditions Handbook provides all OCJS projects are required to submit Quarterly Subgrant Reports. This report must show actual expenditures, describe progress towards achieving objectives, and include supporting documentation (such as purchase orders, vouchers, invoices, payroll allocation reports, payroll summaries, timesheets, etc.) for expenditures. The reports shall be submitted no later than the last day of the month following the calendar quarter end. A report must be submitted every quarter, even when there has been zero expenditure or when a payment is not being requested. • The City submitted the quarterly report for the quarter ending March 31, 2023 for the COVID-19: Coronavirus State And Local Fiscal Recovery Funds AL# 21.027 Marietta Municipal Court Diversion/Backlog Grant 2022ARCCB1134 after the required deadline. • The City submitted the quarterly report for the quarter ending March 31, 2023 for the COVID-19: Coronavirus State And Local Fiscal Recovery Funds AL# 21.027 Employee Retention Grant 2022-AR-LEP-937 after the required deadline. Further, the City did not submit a report for the quarter ended September 30, 2023. The failure to timely submit the required reports was due to insufficient controls and could result in action taken by the pass-through entity. The City should establish procedures to help ensure all required reports are submitted timely.
Finding Number: 2023-003 Assistance Listing Number and Title: Coronavirus State And Local Fiscal Recovery Funds AL # 21.027 Federal Award Identification Number: 2022ARCCB1134/ 2022-AR-LEP-937 Federal Agency: U.S. Department of Treasury Compliance Requirement: Reporting Pass-Through Entity: Ohio Department of Public Safety Repeat Finding from Prior Audit? No Noncompliance and Material Weakness 2 CFR § 1000.10 gives regulatory effect to Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200 for the Department of Treasury. 2 CFR 200.329 provides the recipient and subrecipient are responsible for the oversight of the Federal award. The recipient and subrecipient must monitor their activities under Federal awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient and subrecipient must cover each program, function, or activity. The Office of Criminal Justice Service Standard Subgrant Conditions Handbook provides all OCJS projects are required to submit Quarterly Subgrant Reports. This report must show actual expenditures, describe progress towards achieving objectives, and include supporting documentation (such as purchase orders, vouchers, invoices, payroll allocation reports, payroll summaries, timesheets, etc.) for expenditures. The reports shall be submitted no later than the last day of the month following the calendar quarter end. A report must be submitted every quarter, even when there has been zero expenditure or when a payment is not being requested. • The City submitted the quarterly report for the quarter ending March 31, 2023 for the COVID-19: Coronavirus State And Local Fiscal Recovery Funds AL# 21.027 Marietta Municipal Court Diversion/Backlog Grant 2022ARCCB1134 after the required deadline. • The City submitted the quarterly report for the quarter ending March 31, 2023 for the COVID-19: Coronavirus State And Local Fiscal Recovery Funds AL# 21.027 Employee Retention Grant 2022-AR-LEP-937 after the required deadline. Further, the City did not submit a report for the quarter ended September 30, 2023. The failure to timely submit the required reports was due to insufficient controls and could result in action taken by the pass-through entity. The City should establish procedures to help ensure all required reports are submitted timely.
Finding Number: 2023-003 Assistance Listing Number and Title: Coronavirus State And Local Fiscal Recovery Funds AL # 21.027 Federal Award Identification Number: 2022ARCCB1134/ 2022-AR-LEP-937 Federal Agency: U.S. Department of Treasury Compliance Requirement: Reporting Pass-Through Entity: Ohio Department of Public Safety Repeat Finding from Prior Audit? No Noncompliance and Material Weakness 2 CFR § 1000.10 gives regulatory effect to Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200 for the Department of Treasury. 2 CFR 200.329 provides the recipient and subrecipient are responsible for the oversight of the Federal award. The recipient and subrecipient must monitor their activities under Federal awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient and subrecipient must cover each program, function, or activity. The Office of Criminal Justice Service Standard Subgrant Conditions Handbook provides all OCJS projects are required to submit Quarterly Subgrant Reports. This report must show actual expenditures, describe progress towards achieving objectives, and include supporting documentation (such as purchase orders, vouchers, invoices, payroll allocation reports, payroll summaries, timesheets, etc.) for expenditures. The reports shall be submitted no later than the last day of the month following the calendar quarter end. A report must be submitted every quarter, even when there has been zero expenditure or when a payment is not being requested. • The City submitted the quarterly report for the quarter ending March 31, 2023 for the COVID-19: Coronavirus State And Local Fiscal Recovery Funds AL# 21.027 Marietta Municipal Court Diversion/Backlog Grant 2022ARCCB1134 after the required deadline. • The City submitted the quarterly report for the quarter ending March 31, 2023 for the COVID-19: Coronavirus State And Local Fiscal Recovery Funds AL# 21.027 Employee Retention Grant 2022-AR-LEP-937 after the required deadline. Further, the City did not submit a report for the quarter ended September 30, 2023. The failure to timely submit the required reports was due to insufficient controls and could result in action taken by the pass-through entity. The City should establish procedures to help ensure all required reports are submitted timely.
Finding Number: 2023-003 Assistance Listing Number and Title: Coronavirus State And Local Fiscal Recovery Funds AL # 21.027 Federal Award Identification Number: 2022ARCCB1134/ 2022-AR-LEP-937 Federal Agency: U.S. Department of Treasury Compliance Requirement: Reporting Pass-Through Entity: Ohio Department of Public Safety Repeat Finding from Prior Audit? No Noncompliance and Material Weakness 2 CFR § 1000.10 gives regulatory effect to Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200 for the Department of Treasury. 2 CFR 200.329 provides the recipient and subrecipient are responsible for the oversight of the Federal award. The recipient and subrecipient must monitor their activities under Federal awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient and subrecipient must cover each program, function, or activity. The Office of Criminal Justice Service Standard Subgrant Conditions Handbook provides all OCJS projects are required to submit Quarterly Subgrant Reports. This report must show actual expenditures, describe progress towards achieving objectives, and include supporting documentation (such as purchase orders, vouchers, invoices, payroll allocation reports, payroll summaries, timesheets, etc.) for expenditures. The reports shall be submitted no later than the last day of the month following the calendar quarter end. A report must be submitted every quarter, even when there has been zero expenditure or when a payment is not being requested. • The City submitted the quarterly report for the quarter ending March 31, 2023 for the COVID-19: Coronavirus State And Local Fiscal Recovery Funds AL# 21.027 Marietta Municipal Court Diversion/Backlog Grant 2022ARCCB1134 after the required deadline. • The City submitted the quarterly report for the quarter ending March 31, 2023 for the COVID-19: Coronavirus State And Local Fiscal Recovery Funds AL# 21.027 Employee Retention Grant 2022-AR-LEP-937 after the required deadline. Further, the City did not submit a report for the quarter ended September 30, 2023. The failure to timely submit the required reports was due to insufficient controls and could result in action taken by the pass-through entity. The City should establish procedures to help ensure all required reports are submitted timely.
Finding Number: 2023-003 Assistance Listing Number and Title: Coronavirus State And Local Fiscal Recovery Funds AL # 21.027 Federal Award Identification Number: 2022ARCCB1134/ 2022-AR-LEP-937 Federal Agency: U.S. Department of Treasury Compliance Requirement: Reporting Pass-Through Entity: Ohio Department of Public Safety Repeat Finding from Prior Audit? No Noncompliance and Material Weakness 2 CFR § 1000.10 gives regulatory effect to Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200 for the Department of Treasury. 2 CFR 200.329 provides the recipient and subrecipient are responsible for the oversight of the Federal award. The recipient and subrecipient must monitor their activities under Federal awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient and subrecipient must cover each program, function, or activity. The Office of Criminal Justice Service Standard Subgrant Conditions Handbook provides all OCJS projects are required to submit Quarterly Subgrant Reports. This report must show actual expenditures, describe progress towards achieving objectives, and include supporting documentation (such as purchase orders, vouchers, invoices, payroll allocation reports, payroll summaries, timesheets, etc.) for expenditures. The reports shall be submitted no later than the last day of the month following the calendar quarter end. A report must be submitted every quarter, even when there has been zero expenditure or when a payment is not being requested. • The City submitted the quarterly report for the quarter ending March 31, 2023 for the COVID-19: Coronavirus State And Local Fiscal Recovery Funds AL# 21.027 Marietta Municipal Court Diversion/Backlog Grant 2022ARCCB1134 after the required deadline. • The City submitted the quarterly report for the quarter ending March 31, 2023 for the COVID-19: Coronavirus State And Local Fiscal Recovery Funds AL# 21.027 Employee Retention Grant 2022-AR-LEP-937 after the required deadline. Further, the City did not submit a report for the quarter ended September 30, 2023. The failure to timely submit the required reports was due to insufficient controls and could result in action taken by the pass-through entity. The City should establish procedures to help ensure all required reports are submitted timely.
FINDING 2023-002 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): 400ARPHLTHISSCH Pass-Through Entity: Indiana Department of Health Compliance Requirement: Reporting Audit Findings: Significant Deficiency, Other Matters Repeat Finding This is a similar finding from the immediately prior audit report. The prior audit finding number was 2022-004. Condition and Context The County Health Department (Health Department) was awarded the Health Issues and Challenges Grant through the Indiana Department of Health (IDOH), financed through the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds. The grant was funded through the American Rescue Plan Act that focused on the improvement of chronic disease and, more specifically, elevated blood lead level reduction. INDIANA STATE BOARD OF ACCOUNTS 17 ELKHART COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Monthly Reimbursement Submissions The Health Department was required to submit data through the online portal, the National Electronic Disease Surveillance System (NEDSS) Base System (NBS), each month. The submitted data included program specific metrics related to patient case management of certified Elevated Blood Lead Levels (EBLLs). A Case Manager managed all aspects of an individual patient's care. A home visit and two assessments were completed by the Case Manager and input into the NBS. Once these steps were marked as complete in the NBS, the Clinical Manager reviewed each case and compiled data along with the cost reimbursement amount into a spreadsheet. The Clinical Manager provided the spreadsheet to the Manager of Administration who then completed and submitted the reimbursement invoice to the IDOH. The reimbursement invoice was submitted without a documented oversight, review, or approval process to ensure the accuracy of the data prior to submission. Data and Health Equity Report Beginning in October 2022, the Health Department was required to submit program specific metrics and work plan data through the RedCap software on a quarterly basis. The Case Manager was responsible for tracking and compiling the necessary information for the quarterly reports. Of the four reports tested, two reports were submitted late. In addition, the quarterly reports were submitted by the Case Manager via the RedCap software without a documented oversight, review, or approval process to ensure timely submission. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.329(c)(1) states in part: "The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period . . ." INDIANA STATE BOARD OF ACCOUNTS 18 ELKHART COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The issues with the reimbursement submissions and Data and Health Equity reporting processes stem from the lack of a formal oversight and review procedure to ensure accuracy and timeliness. Without a structured verification process before submission, potential errors and inconsistencies could go undetected, thus increasing the likelihood of inaccurate data reporting. Additionally, the reliance on individual staff members to compile and submit reports without secondary review created inefficiencies and contributed to delays, as evidenced by the late submission of two quarterly reports. Effect The lack of oversight and review of the reimbursement submissions and Data and Health Equity reporting process could result in increased risk of inaccurate data being reported to the IDOH, which could compromise the integrity of the program's performance metrics. The absence of a structed verification process can also lead to inefficiencies, as error or inconsistencies may have required corrections after submission, resulting in inefficient use of time and resources. Additionally, the late submission of two quarterly reports indicated a failure to meet reporting deadlines, which could negatively impact compliance with grant requirements and potentially jeopardize future funding opportunities. Questioned Costs There were no questioned costs identified. Recommendation We recommended the Health Department implement a formal oversight and review process for all data submissions to ensure accuracy and completeness before they are submitted to the IDOH. This would involve a secondary review by a designated individual or team to verify the data. Additionally, improving workflow coordination through clearly defined roles and responsibilities for each team member would help streamline the process and prevent delays. To further improve timeliness, the Health Department should implement a tracking and reminder system for report due dates and reimbursement deadlines to ensure timely submissions. Providing staff with thorough training on reporting protocols and maintaining detailed documentation will help ensure consistent adherence to procedures. Finally, establishing accountability measures through clear roles, deadlines, and regular audits would enhance the efficiency and effectiveness of the reporting process. These steps will help ensure the Health Department meets grant requirements, maintains data accuracy, and avoids potential delays or issues in future submissions. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2 CFR § 1000 gives regulatory effect to the United States Department of Treasury for 2 CFR § 200.328 and 200.329(c)(1) which states, in part, that unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly. Testing over the Village's quarterly reporting requirements for the SLFRF program identified only one quarterly report being submitted on September 9, 2022 which was prior to any SLFRF funding expenditures being made. The SLFRF funding expenditures began on February 2, 2023 with no additional quarterly reports submitted. The Village was unable to provide support to show that the Final Reporting requirement was met. Failure to timely submit the required reports to the pass-through entity could result in material noncompliance and potential loss of future funding.
FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): IN0263 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-004. Condition and Context Prior to receipt of direct State and Local Fiscal Recovery Funds (SLFRF) award funds, all eligible entities were required to execute a Financial Assistance Agreement (Agreement), which included the award terms and conditions that recipients must comply with in carrying out the objectives of their award. Per the Agreement, the City was responsible for the effective administration of the federal award, as well as the application of sound management practices and administration of federal funds in a manner consistent with program objectives and terms and conditions of the award. Activities Allowed or Unallowed, Allowable Costs/Cost Principles As part of sound management of the federal award, the City was responsible for implementing a system of internal controls that would ensure compliance with the applicable requirements. The City had not properly designed or implemented such a system. There was no evidence of segregation of duties, such as an oversight, review, or approval process related to these expenditures that would have ensured that expenditures of award funds were made only for activities and costs that were allowable under the federal award and federal regulations. The City passed Ordinance 2022-45 approving a "commitment of up to but not to exceed $400,000 for Infrastructure at the Junction." However, the City made no formal agreements for the payment of claims in relation to the "Junction" Project. Of the ten claims paid with SLFRF funds during 2023, two claims totaling $400,000 were for the "Junction" project. Both claims were paid without itemized invoices and adequate supporting documentation to support amounts paid. INDIANA STATE BOARD OF ACCOUNTS 19 CITY OF LOGANSPORT SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Additionally, the City did not ensure a proper system of internal controls was in place to accurately track expenditures for the SLFRF grant. In 2022, $2.5 million of SLFRF grant funds were transferred out of the City's SLFRF fund into the City of Logansport Project Fund at a financial institution in the name of the City (bank account) and were subsequently comingled with other nonfederal funds as part of a Build Operate Transfer (BOT) Agreement. Of this $2.5 million, $1,626,043 was spent during 2022, leaving $873,957 of the original $2.5 million to be spent in 2023. During 2023, the City disbursed $4,369,454 from its BOT bank account, where SLFRF and other funding sources were comingled without tracking which expenditures were expressly for the purpose of SLFRF. It was not possible to obtain a population of federal expenditures for the BOT expenditures due to this comingling; therefore, a portion of the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements could not be tested. Costs totaling $1,273,957 were not properly documented and were considered questioned costs. The lack of internal controls and noncompliance was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302 states in part: "(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 own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. . . . (b) The financial management system of each non-Federal entity must provide for the following . . . (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number and year, name of the Federal agency, and name of the pass-through entity, if any. INDIANA STATE BOARD OF ACCOUNTS 20 CITY OF LOGANSPORT SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. . . ." 2 CFR 200.400 states in part: "The application of these cost principles is based on the fundamental premises that: (a) The non-Federal entity is responsible for the efficient and effective administration of the Federal award through the application of sound management practices. (b) The non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. (c) The non-Federal entity, in recognition of its own unique combination of staff, facilities, and experience, has the primary responsibility for employing whatever form of sound organization and management techniques may be necessary in order to assure proper and efficient administration of the Federal award. . . ." 2 CFR 200.403(g) states in part: "Be adequately documented. . . ." 2 CFR 200.404 states in part: "A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non- Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: . . . (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award's cost." Cause Due to the lack of internal controls, the City was unable to differentiate expenditures made from federal and nonfederal funds once it commingled nonfederal funds and federal grant awards in a single bank account. Additionally, the City did not obtain appropriate supporting documentation for federal expenditures. INDIANA STATE BOARD OF ACCOUNTS 21 CITY OF LOGANSPORT SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The City was unable to identify all the expenditures paid with federal funds and cannot ensure, nor can we determine, expenditures of the grant were not unallowable and adhered to established practices and polices. This could result in the misuse of funds and the potential loss of funding for future federal awards. Questioned Costs We identified $1,273,957 in known questioned costs as noted above in the Condition and Context. Recommendation We recommended that management of the City establish a system of internal controls to ensure that grant award funds are accounted for and tracked in a designated grant fund. All activity of the grant should be in this fund with supporting documentation for each transaction. Additionally, the City should obtain appropriate supporting documentation for all federal grant expenditures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2023 – 004 Reporting Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP3738 11/30/2021 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit performance reports required by Federal award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the reported projects and expenditures accurately reflect what is reported in the expenditure detail and amounts obligated should reflect total procurement amounts awarded. Condition: While the correct expenditures were reported on the schedule of expenditures of federal awards, the expenditure reports filed during the year did not accurately report project details. Cumulative expenditures should report amounts expended through the end of the period and cumulative obligations should report total procurement amounts awarded. Questioned costs: None Context: The County incorrectly reported cumulative expenditures and cumulative obligations in 4 of 4 reports tested. Cause: Total cumulative expenditures were not reconciled to total amounts reported in the ledger. Reported project obligations were based on projects costs that been incurred and not contract sum awarded. Effect: Noncompliance with reporting requirements. Repeat Finding: This finding is a partial repeat of a finding in the prior year. The prior year finding number was 2022-004. Recommendation: We recommend the County strengthen its review procedures over reports. Total cumulative expenditures and total cumulative obligations reported should reconcile to the total amounts reported in the project accounting records used to support the SEFA. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP4201 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit performance reports required by Federal award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the reported projects and expenditures accurately reflect what is reported in the expenditure detail and amounts obligated should reflect total procurement amounts awarded. Condition: While the correct expenditures were reported on the schedule of expenditures of federal awards, the performance report filed during the year did not accurately report project details. Current period expenditures and obligations should have reported amounts expended and procurement amounts awarded during the reporting period and cumulative expenditure and obligations should have reported amounts expended and procurement amounts awarded from the start of the grant through the end of the reporting period. Questioned costs: None Context: 1 of 1 tested for reporting documentation. Cause: Total current period expenditures and obligations and total cumulated expenditures and obligations were not reconciled to the expenditure detail and procurement award detail. Prior period performance report overstated current period expenditures and obligations. These errors were corrected through current period performance report tested which causes current period expenditures and obligations to be understated. Effect: Cost could be disallowed as UGG not followed. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2022-005. Recommendation: We recommend the County perform a reconciliation of the project details reported to the expenditure detail and procurement amounts awarded detail used to support the SEFA, and these reconciliations be reviewed, to ensure accuracy and completeness of the reporting. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 004 Reporting Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP3738 11/30/2021 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit performance reports required by Federal award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the reported projects and expenditures accurately reflect what is reported in the expenditure detail and amounts obligated should reflect total procurement amounts awarded. Condition: While the correct expenditures were reported on the schedule of expenditures of federal awards, the expenditure reports filed during the year did not accurately report project details. Cumulative expenditures should report amounts expended through the end of the period and cumulative obligations should report total procurement amounts awarded. Questioned costs: None Context: The County incorrectly reported cumulative expenditures and cumulative obligations in 4 of 4 reports tested. Cause: Total cumulative expenditures were not reconciled to total amounts reported in the ledger. Reported project obligations were based on projects costs that been incurred and not contract sum awarded. Effect: Noncompliance with reporting requirements. Repeat Finding: This finding is a partial repeat of a finding in the prior year. The prior year finding number was 2022-004. Recommendation: We recommend the County strengthen its review procedures over reports. Total cumulative expenditures and total cumulative obligations reported should reconcile to the total amounts reported in the project accounting records used to support the SEFA. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2202ILLIEA 10/1/2021; G-2202ILLIEA 10/1/2021; G-2302ILLIEA 10/1/2022; 2102ILLWCS 5/28/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 22-221038; 22-224038; 23-224038; 21-233038 Award Period: June 1, 2022 through September 30, 2023, October 1, 2021 through June 30, 2023, October 1, 2022 through June 30, 2024, and September 1, 2021 through August 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit financial reports required by the pass through entity award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the periodic financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the periodic financial reporting accounting records were not maintained. Additionally, the accounting records supporting the SEFA did not agree to the grant reconciliation submitted with the grant close-out packages tested, and they were not filed by the due date. Questioned costs: None Context: 5 of 5 periodic financial reports tested did not have supporting documentation retained. 3 of 3 financial close out reports did not reconcile to supporting documentation and were late. Cause: Support for the periodic financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close-out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-007. Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the periodic financial reporting and grant close-out reports and documentation be retained. A detailed, documented review of all reports should occur by someone other than the preparer, to ensure the reports are accurate, supported, and filed timely. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP4201 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit performance reports required by Federal award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the reported projects and expenditures accurately reflect what is reported in the expenditure detail and amounts obligated should reflect total procurement amounts awarded. Condition: While the correct expenditures were reported on the schedule of expenditures of federal awards, the performance report filed during the year did not accurately report project details. Current period expenditures and obligations should have reported amounts expended and procurement amounts awarded during the reporting period and cumulative expenditure and obligations should have reported amounts expended and procurement amounts awarded from the start of the grant through the end of the reporting period. Questioned costs: None Context: 1 of 1 tested for reporting documentation. Cause: Total current period expenditures and obligations and total cumulated expenditures and obligations were not reconciled to the expenditure detail and procurement award detail. Prior period performance report overstated current period expenditures and obligations. These errors were corrected through current period performance report tested which causes current period expenditures and obligations to be understated. Effect: Cost could be disallowed as UGG not followed. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2022-005. Recommendation: We recommend the County perform a reconciliation of the project details reported to the expenditure detail and procurement amounts awarded detail used to support the SEFA, and these reconciliations be reviewed, to ensure accuracy and completeness of the reporting. Views of responsible officials: There is no disagreement with the audit finding.
FINDING 2023-002 Federal Program Information: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Transitional Living for Homeless Youth (ALN 93.550) Basic Center Grant (ALN 93.623) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting: The non-federal entity must submit performance reports at the interval required by the federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity (2 CFR 200.329 (c)(1)). Condition: For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Cause: Lack of administrative oversight in regard to periodic reporting. Effect or Potential Effect: The Organization was not in compliance with the reporting requirements. Questioned Costs: None. Context: The U.S. Department of Health and Human Services requires semi-annual federal financial reports be submitted into the HHS Payment Management System (PMS) and semi-annual performance progress reports be submitted into the GrantSolutions system 30 days after the end of the semi-annual period. For 2 semi-annual financial reports selected and 2 semi-annual performance report selected, the reports were not submitted within the required timeframe. The pass-through entity, Mecklenburg County, requires subrecipients to submit monthly expenditure and performance reports via email 15 days after each month end. For 2 months selected, the reports were not submitted within the required timeframe. For 3 months selected, the Organization was unable to provide evidence of submission. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Organization enhance its procedures to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions: To prevent further late reports, internal calendar notifications will be added to the Executive Director and Program Director’s calendars. The Director of Finance & Business will monitor status of report submissions. The Chief of Staff of the program will maintain adequate documentation of report submissions.
FINDING 2023-002 Federal Program Information: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Transitional Living for Homeless Youth (ALN 93.550) Basic Center Grant (ALN 93.623) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting: The non-federal entity must submit performance reports at the interval required by the federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity (2 CFR 200.329 (c)(1)). Condition: For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Cause: Lack of administrative oversight in regard to periodic reporting. Effect or Potential Effect: The Organization was not in compliance with the reporting requirements. Questioned Costs: None. Context: The U.S. Department of Health and Human Services requires semi-annual federal financial reports be submitted into the HHS Payment Management System (PMS) and semi-annual performance progress reports be submitted into the GrantSolutions system 30 days after the end of the semi-annual period. For 2 semi-annual financial reports selected and 2 semi-annual performance report selected, the reports were not submitted within the required timeframe. The pass-through entity, Mecklenburg County, requires subrecipients to submit monthly expenditure and performance reports via email 15 days after each month end. For 2 months selected, the reports were not submitted within the required timeframe. For 3 months selected, the Organization was unable to provide evidence of submission. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Organization enhance its procedures to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions: To prevent further late reports, internal calendar notifications will be added to the Executive Director and Program Director’s calendars. The Director of Finance & Business will monitor status of report submissions. The Chief of Staff of the program will maintain adequate documentation of report submissions.
FINDING 2023-002 Federal Program Information: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Transitional Living for Homeless Youth (ALN 93.550) Basic Center Grant (ALN 93.623) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting: The non-federal entity must submit performance reports at the interval required by the federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity (2 CFR 200.329 (c)(1)). Condition: For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Cause: Lack of administrative oversight in regard to periodic reporting. Effect or Potential Effect: The Organization was not in compliance with the reporting requirements. Questioned Costs: None. Context: The U.S. Department of Health and Human Services requires semi-annual federal financial reports be submitted into the HHS Payment Management System (PMS) and semi-annual performance progress reports be submitted into the GrantSolutions system 30 days after the end of the semi-annual period. For 2 semi-annual financial reports selected and 2 semi-annual performance report selected, the reports were not submitted within the required timeframe. The pass-through entity, Mecklenburg County, requires subrecipients to submit monthly expenditure and performance reports via email 15 days after each month end. For 2 months selected, the reports were not submitted within the required timeframe. For 3 months selected, the Organization was unable to provide evidence of submission. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Organization enhance its procedures to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions: To prevent further late reports, internal calendar notifications will be added to the Executive Director and Program Director’s calendars. The Director of Finance & Business will monitor status of report submissions. The Chief of Staff of the program will maintain adequate documentation of report submissions.
FINDING 2023-002 Federal Program Information: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Transitional Living for Homeless Youth (ALN 93.550) Basic Center Grant (ALN 93.623) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting: The non-federal entity must submit performance reports at the interval required by the federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity (2 CFR 200.329 (c)(1)). Condition: For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Cause: Lack of administrative oversight in regard to periodic reporting. Effect or Potential Effect: The Organization was not in compliance with the reporting requirements. Questioned Costs: None. Context: The U.S. Department of Health and Human Services requires semi-annual federal financial reports be submitted into the HHS Payment Management System (PMS) and semi-annual performance progress reports be submitted into the GrantSolutions system 30 days after the end of the semi-annual period. For 2 semi-annual financial reports selected and 2 semi-annual performance report selected, the reports were not submitted within the required timeframe. The pass-through entity, Mecklenburg County, requires subrecipients to submit monthly expenditure and performance reports via email 15 days after each month end. For 2 months selected, the reports were not submitted within the required timeframe. For 3 months selected, the Organization was unable to provide evidence of submission. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Organization enhance its procedures to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions: To prevent further late reports, internal calendar notifications will be added to the Executive Director and Program Director’s calendars. The Director of Finance & Business will monitor status of report submissions. The Chief of Staff of the program will maintain adequate documentation of report submissions.
Compliance with Reporting Requirements Federal Agency: U.S. Department of Education Information on Federal Program: Client Assistance Program, Assistance Listing 84.161 Criteria: 2 CFR section 200.329 requires the submission of Federal Financial Report SF-425, annually. Statement of Condition: Our testing over financial reporting included the timely submission of the annual report during DRNY’s fiscal year-end. The annual report for Contract H161A220065 due October 31, 2022, was not filed until November 15, 2022. We also viewed the report for the FY23 grant, noting it was due October 31, 2023 and submitted October 10, 2023. Statement of Cause: There were some discrepancies in due dates for the annual SF-425 report listed between the grant award notice and the filing website. The filing website had noted in the language that annual reports were due 90 days after the fiscal year-end, in which case, DRNY would have been in compliance. Statement of Effect: Annual reports noted above were not filed within the required reporting deadline. Questioned Costs: None Perspective Information: As part of testing the compliance with the reporting requirements of the program, the submission of the annual SF-425, due within the period under audit, is reviewed for timeliness of submission. Identification of Repeat Finding: No Recommendation: Disability Rights New York should develop a tracking system for when their various grant reports are due based on the grant award notices to ensure timely filing of their annual reports. View of Responsible Officials and Corrective Action Plan: Since the late submissions in November 2022, DRNY has ensured that the SF425s were submitted in accordance with the due dates per the Grant Award notices (GANs). Further DRNY has now calendared within Outlook all the grant reporting requirements required for awards for the next year and created an Excel tracking sheet of all the remaining reporting required for current grants. Both the Executive Director and the CFO have access to this Excel tracking and the calendar invites. As new GANs are received, the CFO will calendar in the tracking document all reporting requirements and within Outlook send out invites each calendar year and copy the Executive Director on those calendar invites. CFO will confirm to Executive Director as these reports are complete and document in the Excel tracker. Danielle Myers, CFO, is responsible for the resolution of this corrective action plan by 3/1/2024.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Treasury Department Federal Financial Assistance Listing 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement – Reporting Material Weakness in Internal Control over Compliance Criteria: Non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly, except in unusual circumstances, using a form or format authorized by OMB (2 CFR section 200.329). They also may be required to submit special reports as required by the terms and conditions of the federal award. For the Coronavirus State and Local Fiscal Recovery Funds, the City is required to submit the Project and Expenditure Report quarterly. Condition: We noted that while the City submitted the reports as required, the reports contained errors including incorrect amounts and reporting information on the incorrect line items. Cause: The City did not have processes in place to ensure that amounts and information being reported to the Treasury contained accurate and complete information, and that the information being reported was on the correct line. Effect: The City submitted inaccurate reports to Treasury. While the City ultimately corrected the reports with their final annual report submission, the timing of the corrected report was outside the Treasury allowed timeframe of 60 days after the report. Questioned Costs: None reported. Context/Sampling: Sampling was not used as 100% of the reports that were required to be submitted were tested. Repeat Finding from Prior Year(s): No Recommendation: The City should review their current practices and procedures for federal compliance reporting to ensure that the information being reported is complete and accurate. Views of Responsible Officials: The City concurs with the auditor’s findings.
U.S. Treasury Department Federal Financial Assistance Listing 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement – Reporting Material Weakness in Internal Control over Compliance Criteria: Non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly, except in unusual circumstances, using a form or format authorized by OMB (2 CFR section 200.329). They also may be required to submit special reports as required by the terms and conditions of the federal award. For the Coronavirus State and Local Fiscal Recovery Funds, the City is required to submit the Project and Expenditure Report quarterly. Condition: We noted that while the City submitted the reports as required, the reports contained errors including incorrect amounts and reporting information on the incorrect line items. Cause: The City did not have processes in place to ensure that amounts and information being reported to the Treasury contained accurate and complete information, and that the information being reported was on the correct line. Effect: The City submitted inaccurate reports to Treasury. While the City ultimately corrected the reports with their final annual report submission, the timing of the corrected report was outside the Treasury allowed timeframe of 60 days after the report. Questioned Costs: None reported. Context/Sampling: Sampling was not used as 100% of the reports that were required to be submitted were tested. Repeat Finding from Prior Year(s): No Recommendation: The City should review their current practices and procedures for federal compliance reporting to ensure that the information being reported is complete and accurate. Views of Responsible Officials: The City concurs with the auditor’s findings.
Finding 2023-007 – Reporting (Significant Deficiency and Noncompliance) Information on the federal program: U.S. Department of Health and Human Services, Assistance Listing #93.137 Community Programs to Improve Minority Health Grant Program. Criteria: 2 CFR section 200.328 establishes the requirements for timely and accurate financial reporting requirements and 2 CFR 200.329 establishes responsibility for reporting activities under the grant. Both financial and programmatic reporting requires the nonfederal entity to establish internal controls to ensure accuracy of reports. Condition: We tested on financial and one programmatic report filed for this grant during the year. For the programmatic report, data reported for accomplishments and clients served was not clearly supported. In addition, review and approval of the report was not clearly documented. Cause: Results reported in the programmatic report were supported by time sheets and client internal notes. This support was not summarized or categorized in a manner in which the reported data could be traced back to the support. Employees involved in the preparing and filing of these reports are copied on email submission but a review and approval prior to submission was not documented. Effect: The Council did not comply with reporting control requirements. Questioned Costs: None reported Recommendation: We recommend the Council strengthen procedures and documentation policies to ensure program accomplishments are adequately supported by records that are accumulated and summarized in accordance with the required criteria. Procedures should also be strengthened to include a clear review and approval process to be documented prior to report submission. Views of Responsible Officials: See Management’s View and Corrective Action Plan at the end of the report.
FINDING 2023-002 Federal Program Information: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Transitional Living for Homeless Youth (ALN 93.550) Basic Center Grant (ALN 93.623) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting: The non-federal entity must submit performance reports at the interval required by the federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity (2 CFR 200.329 (c)(1)). Condition: For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Cause: Lack of administrative oversight in regard to periodic reporting. Effect or Potential Effect: The Organization was not in compliance with the reporting requirements. Questioned Costs: None. Context: The U.S. Department of Health and Human Services requires semi-annual federal financial reports be submitted into the HHS Payment Management System (PMS) and semi-annual performance progress reports be submitted into the GrantSolutions system 30 days after the end of the semi-annual period. For 2 semi-annual financial reports selected and 2 semi-annual performance report selected, the reports were not submitted within the required timeframe. The pass-through entity, Mecklenburg County, requires subrecipients to submit monthly expenditure and performance reports via email 15 days after each month end. For 2 months selected, the reports were not submitted within the required timeframe. For 3 months selected, the Organization was unable to provide evidence of submission. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Organization enhance its procedures to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions: To prevent further late reports, internal calendar notifications will be added to the Executive Director and Program Director’s calendars. The Director of Finance & Business will monitor status of report submissions. The Chief of Staff of the program will maintain adequate documentation of report submissions.
FINDING 2023-002 Federal Program Information: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Transitional Living for Homeless Youth (ALN 93.550) Basic Center Grant (ALN 93.623) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting: The non-federal entity must submit performance reports at the interval required by the federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity (2 CFR 200.329 (c)(1)). Condition: For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Cause: Lack of administrative oversight in regard to periodic reporting. Effect or Potential Effect: The Organization was not in compliance with the reporting requirements. Questioned Costs: None. Context: The U.S. Department of Health and Human Services requires semi-annual federal financial reports be submitted into the HHS Payment Management System (PMS) and semi-annual performance progress reports be submitted into the GrantSolutions system 30 days after the end of the semi-annual period. For 2 semi-annual financial reports selected and 2 semi-annual performance report selected, the reports were not submitted within the required timeframe. The pass-through entity, Mecklenburg County, requires subrecipients to submit monthly expenditure and performance reports via email 15 days after each month end. For 2 months selected, the reports were not submitted within the required timeframe. For 3 months selected, the Organization was unable to provide evidence of submission. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Organization enhance its procedures to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions: To prevent further late reports, internal calendar notifications will be added to the Executive Director and Program Director’s calendars. The Director of Finance & Business will monitor status of report submissions. The Chief of Staff of the program will maintain adequate documentation of report submissions.
FINDING 2023-002 Federal Program Information: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Transitional Living for Homeless Youth (ALN 93.550) Basic Center Grant (ALN 93.623) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting: The non-federal entity must submit performance reports at the interval required by the federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity (2 CFR 200.329 (c)(1)). Condition: For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Cause: Lack of administrative oversight in regard to periodic reporting. Effect or Potential Effect: The Organization was not in compliance with the reporting requirements. Questioned Costs: None. Context: The U.S. Department of Health and Human Services requires semi-annual federal financial reports be submitted into the HHS Payment Management System (PMS) and semi-annual performance progress reports be submitted into the GrantSolutions system 30 days after the end of the semi-annual period. For 2 semi-annual financial reports selected and 2 semi-annual performance report selected, the reports were not submitted within the required timeframe. The pass-through entity, Mecklenburg County, requires subrecipients to submit monthly expenditure and performance reports via email 15 days after each month end. For 2 months selected, the reports were not submitted within the required timeframe. For 3 months selected, the Organization was unable to provide evidence of submission. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Organization enhance its procedures to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions: To prevent further late reports, internal calendar notifications will be added to the Executive Director and Program Director’s calendars. The Director of Finance & Business will monitor status of report submissions. The Chief of Staff of the program will maintain adequate documentation of report submissions.
FINDING 2023-002 Federal Program Information: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Transitional Living for Homeless Youth (ALN 93.550) Basic Center Grant (ALN 93.623) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting: The non-federal entity must submit performance reports at the interval required by the federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity (2 CFR 200.329 (c)(1)). Condition: For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Cause: Lack of administrative oversight in regard to periodic reporting. Effect or Potential Effect: The Organization was not in compliance with the reporting requirements. Questioned Costs: None. Context: The U.S. Department of Health and Human Services requires semi-annual federal financial reports be submitted into the HHS Payment Management System (PMS) and semi-annual performance progress reports be submitted into the GrantSolutions system 30 days after the end of the semi-annual period. For 2 semi-annual financial reports selected and 2 semi-annual performance report selected, the reports were not submitted within the required timeframe. The pass-through entity, Mecklenburg County, requires subrecipients to submit monthly expenditure and performance reports via email 15 days after each month end. For 2 months selected, the reports were not submitted within the required timeframe. For 3 months selected, the Organization was unable to provide evidence of submission. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Organization enhance its procedures to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions: To prevent further late reports, internal calendar notifications will be added to the Executive Director and Program Director’s calendars. The Director of Finance & Business will monitor status of report submissions. The Chief of Staff of the program will maintain adequate documentation of report submissions.
Compliance with Reporting Requirements Federal Agency: U.S. Department of Education Information on Federal Program: Client Assistance Program, Assistance Listing 84.161 Criteria: 2 CFR section 200.329 requires the submission of Federal Financial Report SF-425, annually. Statement of Condition: Our testing over financial reporting included the timely submission of the annual report during DRNY’s fiscal year-end. The annual report for Contract H161A220065 due October 31, 2022, was not filed until November 15, 2022. We also viewed the report for the FY23 grant, noting it was due October 31, 2023 and submitted October 10, 2023. Statement of Cause: There were some discrepancies in due dates for the annual SF-425 report listed between the grant award notice and the filing website. The filing website had noted in the language that annual reports were due 90 days after the fiscal year-end, in which case, DRNY would have been in compliance. Statement of Effect: Annual reports noted above were not filed within the required reporting deadline. Questioned Costs: None Perspective Information: As part of testing the compliance with the reporting requirements of the program, the submission of the annual SF-425, due within the period under audit, is reviewed for timeliness of submission. Identification of Repeat Finding: No Recommendation: Disability Rights New York should develop a tracking system for when their various grant reports are due based on the grant award notices to ensure timely filing of their annual reports. View of Responsible Officials and Corrective Action Plan: Since the late submissions in November 2022, DRNY has ensured that the SF425s were submitted in accordance with the due dates per the Grant Award notices (GANs). Further DRNY has now calendared within Outlook all the grant reporting requirements required for awards for the next year and created an Excel tracking sheet of all the remaining reporting required for current grants. Both the Executive Director and the CFO have access to this Excel tracking and the calendar invites. As new GANs are received, the CFO will calendar in the tracking document all reporting requirements and within Outlook send out invites each calendar year and copy the Executive Director on those calendar invites. CFO will confirm to Executive Director as these reports are complete and document in the Excel tracker. Danielle Myers, CFO, is responsible for the resolution of this corrective action plan by 3/1/2024.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance This is a repeat of prior year finding #2022-006. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports. Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late. Effect: A lack of controls could result in late or failed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Treasury Department Federal Financial Assistance Listing 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement – Reporting Material Weakness in Internal Control over Compliance Criteria: Non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly, except in unusual circumstances, using a form or format authorized by OMB (2 CFR section 200.329). They also may be required to submit special reports as required by the terms and conditions of the federal award. For the Coronavirus State and Local Fiscal Recovery Funds, the City is required to submit the Project and Expenditure Report quarterly. Condition: We noted that while the City submitted the reports as required, the reports contained errors including incorrect amounts and reporting information on the incorrect line items. Cause: The City did not have processes in place to ensure that amounts and information being reported to the Treasury contained accurate and complete information, and that the information being reported was on the correct line. Effect: The City submitted inaccurate reports to Treasury. While the City ultimately corrected the reports with their final annual report submission, the timing of the corrected report was outside the Treasury allowed timeframe of 60 days after the report. Questioned Costs: None reported. Context/Sampling: Sampling was not used as 100% of the reports that were required to be submitted were tested. Repeat Finding from Prior Year(s): No Recommendation: The City should review their current practices and procedures for federal compliance reporting to ensure that the information being reported is complete and accurate. Views of Responsible Officials: The City concurs with the auditor’s findings.
U.S. Treasury Department Federal Financial Assistance Listing 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement – Reporting Material Weakness in Internal Control over Compliance Criteria: Non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly, except in unusual circumstances, using a form or format authorized by OMB (2 CFR section 200.329). They also may be required to submit special reports as required by the terms and conditions of the federal award. For the Coronavirus State and Local Fiscal Recovery Funds, the City is required to submit the Project and Expenditure Report quarterly. Condition: We noted that while the City submitted the reports as required, the reports contained errors including incorrect amounts and reporting information on the incorrect line items. Cause: The City did not have processes in place to ensure that amounts and information being reported to the Treasury contained accurate and complete information, and that the information being reported was on the correct line. Effect: The City submitted inaccurate reports to Treasury. While the City ultimately corrected the reports with their final annual report submission, the timing of the corrected report was outside the Treasury allowed timeframe of 60 days after the report. Questioned Costs: None reported. Context/Sampling: Sampling was not used as 100% of the reports that were required to be submitted were tested. Repeat Finding from Prior Year(s): No Recommendation: The City should review their current practices and procedures for federal compliance reporting to ensure that the information being reported is complete and accurate. Views of Responsible Officials: The City concurs with the auditor’s findings.
Finding 2023-007 – Reporting (Significant Deficiency and Noncompliance) Information on the federal program: U.S. Department of Health and Human Services, Assistance Listing #93.137 Community Programs to Improve Minority Health Grant Program. Criteria: 2 CFR section 200.328 establishes the requirements for timely and accurate financial reporting requirements and 2 CFR 200.329 establishes responsibility for reporting activities under the grant. Both financial and programmatic reporting requires the nonfederal entity to establish internal controls to ensure accuracy of reports. Condition: We tested on financial and one programmatic report filed for this grant during the year. For the programmatic report, data reported for accomplishments and clients served was not clearly supported. In addition, review and approval of the report was not clearly documented. Cause: Results reported in the programmatic report were supported by time sheets and client internal notes. This support was not summarized or categorized in a manner in which the reported data could be traced back to the support. Employees involved in the preparing and filing of these reports are copied on email submission but a review and approval prior to submission was not documented. Effect: The Council did not comply with reporting control requirements. Questioned Costs: None reported Recommendation: We recommend the Council strengthen procedures and documentation policies to ensure program accomplishments are adequately supported by records that are accumulated and summarized in accordance with the required criteria. Procedures should also be strengthened to include a clear review and approval process to be documented prior to report submission. Views of Responsible Officials: See Management’s View and Corrective Action Plan at the end of the report.
Finding Reference: 2023-003 – Reporting Federal Agency: U.S Department of Agriculture Federal Program: Water and Waste Disposal System for Rural Communities - ALN# 10.760 Compliance Requirement: Reporting Criteria: The Uniform Guidance requires that non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly, except in unusual circumstances, using a form or format authorized by OMB (2 CFR section 200.329). They also may be required to submit special reports as required by the terms and conditions of the federal award. The U.S Department of Agriculture requires the Authority to submit Quarterly Income and Expense Statements. The reports are to be signed by the appropriate borrower official and submitted within 30 days of each quarter’s end. Condition: The Authority has not submitted Quarterly Income and Expense Statements within 30 days of the fiscal quarter end. However, the Authority has submitted audited annual financial reports within 9 months of fiscal year end. Cause and Effect: The Authority was unacquainted with quarterly filing requirements as set forth by the U.S. Department of Agriculture per the loan agreement. Without filing quarterly Income and Expense Statements, USDA is unaware of how funding is spent throughout the year. Questioned Cost: None Identification of Repeat Finding: No Recommendation: The Authority should begin to submit quarterly reports in accordance with loan agreement. Views of Responsible Officials: This was first brought to the Authority’s attention in the current year. The Authority is working towards submitting appropriate reports.
Finding 2023-002: Reporting - Significant Deficiency Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Name and Assistance Listing Number: CCDF Cluster, 93.575 Federal Award Identification Number and Year: 2101HICSC6, 2021 Name of Pass-through Entity: State of Hawaii Department of Human Services Criteria: According to 2 CFR 200.329, management is responsible for ensuring that all reports are submitted timely, in accordance with organizational policies and federal award compliance requirements. Condition: During the audit we noted that the Organization had not retained documentation showing that the required reports were submitted timely. Cause: The Organization's financial management did not retain documentation indicating that the reports were submitted timely. Effect or Potential Effect: This condition may lead to non-compliance with reporting requirements. Questioned Costs: N/A Context: This issue was noted across multiple reporting instances. While management submitted complete and accurate reports, documentation confirming timely submission was not retained. Identification as a Repeat Finding: This is a repeat finding. See 2022-003. Recommendation: We recommend that the Organization implement policies, procedures, and controls to ensure that there are documented and retrievable records to indicate that reports were submitted timely. Views of Responsible Officials: Management concurs with the finding and will ensure that records are maintained to indicate timely submission of reports.