FINDING 2023-006 Subject: COVID-19: Coronavirus State and Local Fiscal Recovery Funds - US 12 Stormwater Drainage Improvement Project - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Number and Year (or Other Identifying Number): TRSW222046 Pass-Through Entity: Indiana Finance Authority Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The City had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties that would likely be effective in preventing, or detecting and correcting, noncompliance. Recipients were required to submit quarterly expenditure reports and a final report to the Indiana Finance Authority. Information to be reported included the expenditures of the grant and the status on the project for the appropriate reporting period. The City should have submitted four expenditure reports and a final report since the grant agreement was signed on February 25, 2022. However, the City only submitted one expenditure report for the fourth quarter and a final report. In addition, a single employee prepared and submitted the progress report without a review or oversight process in place to prevent, or detect and correct, errors. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the missing reports noted above. 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) states: "Non-construction performance reports. The Federal awarding agency must use standard, governmentwide OMB-approved data elements for collection of performance information including performance progress reports, Research Performance Progress Reports. INDIANA STATE BOARD OF ACCOUNTS 24 CITY OF MICHIGAN CITY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (1) The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non- Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance reports as required by the terms and conditions of the Federal award. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report. (2) As appropriate in accordance with above mentioned performance reporting, these reports will contain, for each Federal award, brief information on the following unless other data elements are approved by OMB in the agency information collection request: (i) A comparison of actual accomplishments to the objectives of the Federal award established for the period. Where the accomplishments of the Federal award can be quantified, a computation of the cost (for example, related to units of accomplishment) may be required if that information will be useful. Where performance trend data and analysis would be informative to the Federal awarding agency program, the Federal awarding agency should include this as a performance reporting requirement. (ii) The reasons why established goals were not met, if appropriate. (iii) Additional pertinent information including, when appropriate, analysis and explanation of cost overruns or high unit costs." The Grant Agreement states in part: "The Participant will report to the Finance Authority on the Participant's expenditure of the Grant and the status of the Project on the first day of each quarter following the date of this Agreement, and on the first day of every quarter thereafter until the Participant extends all the Grant funds and completes the Project, whichever is later. At the time the Participant completes the Project, the Participant will provide promptly to the Finance Authority a final report (the "Final Report"). All reports to the Finance Authority will be in form and substance satisfactory to the Finance Authority and as may be required by the United States Department of Treasury . . ." Cause Management had not developed a system of internal controls that would have prevented or detected and allowed for correction of material noncompliance. The City did not complete and submit quarterly reports as required because the officials were unaware of the requirement. INDIANA STATE BOARD OF ACCOUNTS 25 CITY OF MICHIGAN CITY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Without the proper design or implementation of the components of a system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, noncompliance. As such, not all the required reports were not submitted. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the City design and implement a proper system of internal controls, including policies and procedures, to ensure the City completes and submits all required reports. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2023-004 Assistance Listing Number: 21.023 Program Title: COVID-19 Emergency Rental Assistance (ERA) Award Number / Year: 1505-0270 / 2023 Federal Agency: U.S. Department of Treasury Pass-Through Entity: Not applicable Criteria: 2 CFR Part 200.329(b) and ERA Reporting Guidance requires quarterly reporting to the Treasury portal contain all expenditures and obligations to be clearly identified by type including subawards, contracts, direct payments, or beneficiaries. The required information includes identification of subrecipients which are entities that receive a subaward from a recipient to carry out the purposes (program or project) of the ERA award on behalf of the recipient. Subrecipient relationships require additional monitoring and compliance steps. The direct recipient (the County) is responsible for determining if an entity is considered to be a subrecipient. Condition/Context: Both of the two reports selected for testing contained a contractor that was incorrectly reported as a subaward. Our sample was not statistically valid. Cause: The County did not have internal controls in place requiring an independent person with an understanding of the subrecipient terminology and classification to review the report prior to submission to the U.S. Department of Treasury. Effect: The report was submitted with subrecipient misclassifications. Questioned Costs: None noted. Recommendation: The County should review its internal control procedures to ensure there are proper review and approval processes in place over completeness and accuracy of reports before submissions to federal agencies are completed. Management's Response: Effective with the 2024 third quarter reporting, the contractor incorrectly reported as a subaward with Treasury was corrected.
#2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Material Weakness in Internal Controls Over Compliance This is a partial repeat of prior year finding #2022-009. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing that no review procedures are in place surrounding these reports. Cause/Context: Controls were not in place to ensure accurate reporting. Only one individual was involved in the reporting process. Effect: Controls in place do not sufficiently ensure complete, accurate, and timely reporting compliance. Recommendation: We recommend that a full-range of controls related to reporting, including federal program reporting be implemented. The Organization should devote the resources necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval should be documented and that documentation be maintained. Views of Responsible Officials and Planned Corrective Actions: MARR will retain a CPA consultant to implement a full – range of controls relating to reporting, including federal program reporting. MARR will take such steps as necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval will be documented in such documentation to be maintained.
#2023-008 – Major Federal Award Finding – Reporting Nature of Finding: Material Weakness in Internal Controls Over Compliance This is a partial repeat of prior year finding #2022-009. Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing that no review procedures are in place surrounding these reports. Cause/Context: Controls were not in place to ensure accurate reporting. Only one individual was involved in the reporting process. Effect: Controls in place do not sufficiently ensure complete, accurate, and timely reporting compliance. Recommendation: We recommend that a full-range of controls related to reporting, including federal program reporting be implemented. The Organization should devote the resources necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval should be documented and that documentation be maintained. Views of Responsible Officials and Planned Corrective Actions: MARR will retain a CPA consultant to implement a full – range of controls relating to reporting, including federal program reporting. MARR will take such steps as necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval will be documented in such documentation to be maintained.
FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance 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): FY 2023 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit Findings: Material Weakness, Modified Opinion Condition and Context Recipients may use COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) funds for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 and amended by the Consolidated Appropriations Act of 2023. The SLFRF program provides substantial flexibility for each recipient to meet local needs within seven separate eligible use categories. Recipients may use SLFRF funds to: Respond to the COVID-19 public health emergency and its negative economic impacts; Respond to workers performing essential work during the COVID-19 public health emergency by providing premium pay to eligible workers of eligible employers that have eligible workers who are performing essential work; Provide government services, to the extent COVID-19 caused a reduction in revenues collected in the most recent full fiscal year of the recipient; Make necessary investments in water, sewer, or broadband infrastructure; Provide emergency relief from natural disasters or their negative economic impacts; Fund eligible Surface Transportation projects; and Fund Title I projects that are eligible activities under the Community Development Block Grant and Indiana Community Development Block Grant programs. 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 did not properly design or implement such a system. The City elected to receive the standard revenue loss allowance, allowing it to claim its total SLFRF allocation of $2,290,914 as revenue loss to use for government services. The allocated funds may only be used to cover costs incurred from the period beginning on March 3, 2021, and ending on December 31, 2024. Obligations for costs incurred are required to be liquidated no later than December 31, 2026 (the end of the period of performance). During the audit period, the City completed three separate transfers of SLFRF funds from the ARPA Coronavirus Local Fiscal fund to the Comm Crossing Grant Fund and Water Utility-Operating funds, totaling $976,431 and $494,159, respectively. The transfers allowed for federal grant funds to be commingled with other grant and operating funds. Subsequently, expenditures were disbursed from the Comm Crossing Grant Fund and Water Utility-Operating funds. However, since the transfer of SLFRF funds into the Comm Crossing Grant Fund and Water Utility-Operating funds commingled receipts, and the City did not ensure there was an appropriate system of internal controls in place to account for the federal expenditures separately from other grant and operating expenditures, we were unable to determine a complete population of federal expenditures. Without a complete population of expenditures, we were unable to determine the City's compliance with the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. As such, the $976,431 and $494,159 transferred from the ARPA Coronavirus Local Fiscal fund are considered questioned costs. The lack of internal controls and appropriate documentation to test the compliance requirements was isolated to the situation described above. 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 200.300(b) states in part: "The non-Federal entity is responsible for complying with all requirements of the Federal award. . . ." 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. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. . . ." Cause Due to the lack of internal controls, the City was unable to differentiate expenditures made from federal and nonfederal funds once it commingled other grant, operating, and federal grant awards into a single fund within its ledger without consideration of the need to separately identify and account for federal expenditures. Effect Without the proper implementation of an effectively designed system of internal controls, the Town cannot identify the expenditures paid with federal grant funds. As such the Town cannot ensure nor can we determine that expenditures of the grant were not unallowable and fell within the period of performance. Questioned Costs We identified $1,470,590 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. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, and Procurement and Suspension and Debarment 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): PO 20011717 Pass-Through Entity: Indiana State Department of Health Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context The County Department of Health, a department within the County, was awarded the Health Issues and Challenges grant through the Indiana State Department of Health financed through the American Rescue Plan Act for the purpose of funding programs that focus on the improvement of chronic disease, specifically, elevated blood lead level reduction. The Health Issues and Challenges grant is a reimbursable grant, whereby the County received reimbursement on a per-case basis at a stated rate for Case Management and Environmental Investigation activities performed. The County Department of Health received federal receipts related to the grant in the amount of $130,479 during 2023. As part of sound management of the federal award, the County Department of Health was responsible for implementing a system of internal controls that would ensure compliance with the applicable requirements. The County Department of Health did not properly design or implement such a system. Receipts of the program were adequately identified through the use of an account number within the County Health Fund (285) in the County's ledger (ledger) which was unique to the Health Issues and Challenges grant receipts. However, the ledger did not adequately identify the expenditures of the grant program within the County Health Fund. Through inquiry with the County Department of Health employees and review of unit-prepared support of grant expenditures, we determined expenditures were made with grant funds during the audit period; however, we were unable to distinguish between the expenditures of the Health Issues and Challenges grant and all other activities of the County Department of Health in the County Health fund. Due to the lack of separate identification of expenditures in the financial records, we were not able to establish a population from which to audit the Health Issues and Challenges grant for compliance with the following compliance requirements of the program: Activities Allowed or Unallowed Allowable Costs/Cost Principles Period of Performance Procurement and Suspension and Debarment As such, the full award amount of $130,479, as reported on the Schedule of Expenditures of Federal Awards, was determined to be questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.300(b) states in part: "The non-Federal entity is responsible for complying with all requirements of the Federal award. . . ." 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. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. . . ." Cause The County Department of Health was unable to differentiate expenditures made from federal and non-federal funds within its ledger for the Heath Issues and Challenges grant. Effect Without the proper implementation of an effectively designed system of internal controls, a population of expenditures associated with the Health Issues and Challenges grant could not be determined. As such, the County Department of Health cannot ensure nor can we determine that expenditures of the grant were not unallowable, within the proper period, and adhered to established practices and policies. Questioned Costs We identified $130,479 in known questioned costs as noted in the Condition and Context. Recommendation We recommended that management of the County Department of Health establish a system of internal controls to ensure that grant award funds are adequately accounted for and tracked in such a manner as to determine the activity, receipts, and disbursements associated with the grant. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance 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): FY 2023 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to receipt of direct COVID-19 - Coronavirus 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 Town 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. Recipients may use SLFRF funds for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 and amended by the Consolidated Appropriations Act of 2023. The SLFRF program provides substantial flexibility for each recipient to meet local needs within seven separate eligible use categories. Recipients may use SLFRF funds to: Respond to the COVID-19 public health emergency and its negative economic impacts; Respond to workers performing essential work during the COVID-19 public health emergency by providing premium pay to eligible workers of eligible employers that have eligible workers who are performing essential work; INDIANA STATE BOARD OF ACCOUNTS 17 TOWN OF UPLAND SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Provide government services, to the extent COVID-19 caused a reduction in revenues collected in the most recent full fiscal year of the recipient; Make necessary investments in water, sewer, or broadband infrastructure. Provide emergency relief from natural disasters or their negative economic impacts. Fund eligible Surface Transportation projects; and Fund Title I projects that are eligible activities under the Community Development Block Grant and Indiana Community Development Block Grant programs. As part of sound management of the federal award, the Town was responsible for implementing a system of internal controls that would ensure compliance with the applicable requirements. The Town 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, 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 and that were within the period of performance. The Town completed five transfers totaling $224,050 to the Town Utility funds. The amounts transferred to these Utility funds were commingled with other receipts; therefore, the expenditures that went with the SLFRF money, if any, could not be identified. Therefore, the $224,050 could not be tested to ensure compliance with the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. The lack of internal controls and noncompliance were isolated to the transfers noted above. Criteria 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 programspecific 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. (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. . . . INDIANA STATE BOARD OF ACCOUNTS 18 TOWN OF UPLAND SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. . . ." 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). . . ." Cause A proper system of internal controls was not designed by management of the Town. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the Town's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Due to the lack of internal controls, the Town was unable to differentiate expenditures made from federal and nonfederal funds once it commingled nonfederal funds and federal grant awards. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system was not effective in preventing, or detecting and correcting, material noncompliance within the grant. The Town was unable to identify all the expenditures paid with federal funds and cannot ensure, nor can we determine, expenditures of the grant were allowable activity, within the proper period, and were an allowable cost. Questioned Costs We identified $224,050 in known questioned costs as noted above in the Condition and Context. Recommendation We recommended that management of the Town 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. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Type of Finding: Significant Deficiency in Compliance and Internal Control over Compliance Federal Agency: U.S. Department of Defense Federal Program Name: Conservation and Rehabilitation of Natural Resources on Military Installations Assistance Listing Number: 12.005 Federal Award Identification Number and Year: H79TI083313 - 2020 Award Period: September 28, 2020, through September 27, 2025 Criteria or specific requirement: 2 CFR 200.303(a) states that a non-Federal entity must "Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." In addition, 2 CFR 200.329(c)(1) states that “the non-federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity”. Per the award agreement for contract W912DW-20-2-0003, "Recipient shall submit to the Agreement Administrator (see paragraph 1.2.1) progress reports on a quarterly basis utilizing the form included in Attachment B of this agreement. Reports are due no later than 30 days following the end of each reporting period. A final performance progress report shall be submitted within 90 days after the expiration date of the award." Condition: During testing it was noted that 3 of the 6 financial reports tested did not include documentary evidence of Executive Director review and approval. In addition, 2 of the 2 performance reports tested were filed after the filing deadline. Questioned costs: None. Context: A sample of 6 was made from a population of 17 financial reports, and a sample of 2 was made from a population of 4 performance reports. Of the 6 financial reports sampled, 3 did not have documentary evidence of Executive Director review and approval. Of the 2 performance reports sampled, both were filed after the submission deadline date. Cause: Late filing is due to a lack of adherence to the due dates as defined within the contract terms. The Organization does not have adequate controls in place to document the Executive Director's review and approval of the Federal Financial Reports (SF-425). Effect: Not filing reports on a timely basis can present risks, such as outdated and unreliable information or the inability to detect potential fraud or irregularities. In addition, delayed reports can impede regulatory authorities' ability to monitor compliance, detect patterns or trends, and assess risks in a timely manner. Without adequate documentary evidence around the review of financial reports, there is an increased risk of errors and fraud in the reporting process, which could result in inaccurate financial reporting and misappropriation of funds. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: CLA recommends for the Organization to place emphasis on stronger controls around the timely filing of required reports, such as retaining a monthly checklist of required reconciliations and reports. CLA also recommends implementing a procedure that documents the Executive Director's review and approval of the Federal Financial Reports (SF-425s), whether that be via an email chain or retaining a copy that also includes the Executive Director's signature on the report. Views of responsible officials: There is no disagreement with the audit finding.
Program Information: COVID-19 Governor’s Emergency Education Relief Fund (84.425C) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): In accordance with 2 CFR 200.328 and 200.329, the Organization must report financial and programmatic data as required by the terms and conditions of the Federal award. Condition: Evidence of submission could not be provided for certain reports. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The Organization was not in compliance with reporting requirements. Questioned Costs: None. Context: For 3 of 3 reports tested, we were able to confirm that the Organization submitted required reports, however, we were unable to obtain evidence that the reports were submitted by the deadline. Identification as a Repeat Finding: No similar findings were identified in the prior year. Recommendation: We recommend the Organization enhance its procedures and internal controls to ensure that records of report submission are appropriately retained. Views of Responsible Officials and Planned Corrective Actions: The Alliance will enhance its procedures and internal controls to ensure that records of report submission are appropriately retained.
Finding 2023-002: Reportable Finding Considered a Significant Deficiency – Reporting Assistance Listing Number: 10.181 Agency: U.S. Department of Agriculture Program: Pandemic Relief Activities: Farm and Food Worker Relief Program (FFWR) Award Number: AM22FFWDC0002-02 Grant Years: 2023 Criteria: The Performance and Financial Monitoring and Reporting guidelines outlined in 2 CFR sections 200.328 and 200.329 require that the Foundation submit Office of Management and Budget semi-annual financial reporting on Form SF-425. Condition: During our 2023 audit, we reviewed the Forms SF-425 submitted during the period which covered the periods November 4, 2022 through April 3, 2023 and April 4, 2023 through October 3, 2023. We reviewed the submissions for timely submission, that the reports were signed by a certifying official, and that the reports reconciled to the information obtained during the audit of the financial statements. For the SF-425 which covered the period November 4, 2022 through April 3, 2023 we could not reconcile the expenditures in the report to the underlying financial information. Cause: The Foundation did not reconcile the SF-425 to the financial records before submission. Effect: The Foundation reported erroneous amount of federal award expenditures on Form SF-425 for the period November 4, 2022 through April 3, 2023. Context: There were two SF-425 submissions during the year. Questioned Costs: There are no questioned costs associated with this finding. Repeat Finding: This is not a repeat finding. Recommendation: The Foundation should implement internal control procedures to ensure that the amounts reported in Form SF-425 are reconciled to the underlying financial records and reviewed before being signed by a certifying official and submitted. Views of Responsible Officials and Planned Corrective Actions: The views of responsible officials and planned corrective actions is included at the end of this report.
2023-007 – Reporting Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 9/1/23-8/31/25; 4/1/21-3/31/23; 6/1/19-5/31/23; 6/1/23-5/31/26; 12/1/22-5/31/23 Type of Finding: Significant Deficiency in internal control over compliance Criteria or Specific Requirement: § 200.329 indicates that the non-federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Condition: The Organization did not maintain supporting documentation showing an independent review and approval of Federal Financial Reports occurring prior to the reports being filed. Questioned Costs: None. Context: Two of two reports selected for testing did not contain evidence of an independent review occurring prior to the report being filed. Cause: Management turnover. Effect: Incorrect or inaccurate reports could be submitted if they are not reviewed prior to being filed. Repeat Finding: No. Recommendation: The Organization should ensure appropriate supporting documentation is maintained which shows the person who completed the review as well as the date the review was 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 title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 9/1/23-8/31/25; 4/1/21-3/31/23; 6/1/19-5/31/23; 6/1/23-5/31/26; 12/1/22-5/31/23 Type of Finding: Significant Deficiency in internal control over compliance Criteria or Specific Requirement: § 200.329 indicates that the non-federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Condition: The Organization did not maintain supporting documentation showing an independent review and approval of Federal Financial Reports occurring prior to the reports being filed. Questioned Costs: None. Context: Two of two reports selected for testing did not contain evidence of an independent review occurring prior to the report being filed. Cause: Management turnover. Effect: Incorrect or inaccurate reports could be submitted if they are not reviewed prior to being filed. Repeat Finding: No. Recommendation: The Organization should ensure appropriate supporting documentation is maintained which shows the person who completed the review as well as the date the review was 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 title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 9/1/23-8/31/25; 4/1/21-3/31/23; 6/1/19-5/31/23; 6/1/23-5/31/26; 12/1/22-5/31/23 Type of Finding: Significant Deficiency in internal control over compliance Criteria or Specific Requirement: § 200.329 indicates that the non-federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Condition: The Organization did not maintain supporting documentation showing an independent review and approval of Federal Financial Reports occurring prior to the reports being filed. Questioned Costs: None. Context: Two of two reports selected for testing did not contain evidence of an independent review occurring prior to the report being filed. Cause: Management turnover. Effect: Incorrect or inaccurate reports could be submitted if they are not reviewed prior to being filed. Repeat Finding: No. Recommendation: The Organization should ensure appropriate supporting documentation is maintained which shows the person who completed the review as well as the date the review was completed. Views of Responsible Officials: There is no disagreement with the audit finding.
2 CFR 1000.10 gives regulatory effect to the Department of Treasury for 2 CFR part 200. 2 CFR 200.302 states, in part, the non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.302 further states, in part, the financial management system of each non-Federal entity must provide for accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. Additionally, the Ohio Department of Development (ODOD) Water and Wastewater Infrastructure Program Grant Agreement provides in paragraph 1 that “[e]xpenditures shall be supported by contracts, invoices, vouchers, and other data as appropriate, including the reports listed in accordance with the schedule set forth in Exhibit II: Reporting, evidencing the costs incurred.” For funding received directly from the Department of Treasury as an NEU, the Village did not appropriately report the correct cumulative obligations or cumulative expenditures on the April 2023 annual project and expenditure report. This caused an understatement of $17,191 in the April 2023 report. This is due to the misinterpretation of guidance provided to the Village. Failure to accurately report cumulative obligations and cumulative expenditures could result in grants being overspent. For SLFRF funding passed through the Ohio Department of Development, the Village requested reimbursements totaling $61,788 for expenditures that were paid for by funding received directly from the Department of Treasury as an NEU. This was caused due to the Village submitting incorrect invoices to the Engineering Firm. The Village identified the error and worked with ODOD to submit alternative reimbursement requests which were not paid for by other funding sources. These requests were submitted to ODOD September 12, 2024. Failure to submit correct invoices for reimbursement could result in the Village not receiving the reimbursements that it is entitled to. The Village should implement internal controls to ensure the correct amounts are included in reports submitted to the US Department of Treasury and that requests for reimbursement to ODOD only include allowable expenditures not paid by other funding sources.
2 CFR 1000.10 gives regulatory effect to the Department of Treasury for 2 CFR part 200. 2 CFR 200.302 states, in part, the non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.302 further states, in part, the financial management system of each non-Federal entity must provide for accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. Additionally, the Ohio Department of Development (ODOD) Water and Wastewater Infrastructure Program Grant Agreement provides in paragraph 1 that “[e]xpenditures shall be supported by contracts, invoices, vouchers, and other data as appropriate, including the reports listed in accordance with the schedule set forth in Exhibit II: Reporting, evidencing the costs incurred.” For funding received directly from the Department of Treasury as an NEU, the Village did not appropriately report the correct cumulative obligations or cumulative expenditures on the April 2023 annual project and expenditure report. This caused an understatement of $17,191 in the April 2023 report. This is due to the misinterpretation of guidance provided to the Village. Failure to accurately report cumulative obligations and cumulative expenditures could result in grants being overspent. For SLFRF funding passed through the Ohio Department of Development, the Village requested reimbursements totaling $61,788 for expenditures that were paid for by funding received directly from the Department of Treasury as an NEU. This was caused due to the Village submitting incorrect invoices to the Engineering Firm. The Village identified the error and worked with ODOD to submit alternative reimbursement requests which were not paid for by other funding sources. These requests were submitted to ODOD September 12, 2024. Failure to submit correct invoices for reimbursement could result in the Village not receiving the reimbursements that it is entitled to. The Village should implement internal controls to ensure the correct amounts are included in reports submitted to the US Department of Treasury and that requests for reimbursement to ODOD only include allowable expenditures not paid by other funding sources.
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.328 and 2 CFR 200.329 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with the program requirements. Condition: Of three reports tested, two instances in which support was not retained to substantiate federal share of expenditures reported in a quarterly report and the final report. Management subsequently worked to reconcile reports out of the Organization’s accounting software to support federal expenditures reported within the reports that materially agree. Additionally, individual who prepared the report is the same individual approving the report prior to submission to the federal agency. Cause: Support was not retained to substantiate amounts reported within a semi-annual report and final report. Additionally, management hasn’t implemented controls ensuring the individual preparing the report is separate from the individual who reviews and approves the report prior to submission to the federal agency. Effect: Without retaining documentation to support the amounts reported, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Additionally, not having a formal oversight process over reporting results in a reasonable possibility that reports that are inaccurate or incomplete could be submitted. Questioned Costs: None reported. Context/Sampling: Two out of four semi-annual financial reports were reviewed along with one annual financial report. There was a total of five financial reports filed. Repeat Finding from Prior Year: No.
2 CFR § 1000.10 gives regulatory effect to Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200 for the Department of Treasury. 2 CFR 200.329(c)(1) states that non-Federal entities must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Reports submitted quarterly must be due no later than 30 calendar days after the reporting period. 31 CFR 35.4(c) requires recipients, in part, during the period of performance, to provide the Secretary of the U.S. Department of Treasury periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. The U.S. Department of Treasury provided supplementary information on reporting requirements in its interim final rule for State and Local Fiscal Recovery Funds for 31 CFR Part 35 and provided further guidance in its Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guide. The County submitted the required SLFRF Project and Expenditure Reports; however possibly due to the failure of an existing control(s), the expenditures reported on three out of the four (seventy-fifty percent) did not agree to the accounting records with differences ranging from $27,632 to $139,044. Reporting errors could adversely affect future grant awards. An additional control(s) and/or additional procedure(s) should be implemented to help ensure accuracy of the reports.
2 CFR § 1000.10 gives regulatory effect to Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200 for the Department of Treasury. 2 CFR 200.329(c)(1) states that non-Federal entities must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Reports submitted quarterly must be due no later than 30 calendar days after the reporting period. 31 CFR 35.4(c) requires recipients, in part, during the period of performance, to provide the Secretary of the U.S. Department of Treasury periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. The U.S. Department of Treasury provided supplementary information on reporting requirements in its interim final rule for State and Local Fiscal Recovery Funds for 31 CFR Part 35 and provided further guidance in its Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guide. The County submitted the required SLFRF Project and Expenditure Reports; however possibly due to the failure of an existing control(s), the expenditures reported on three out of the four (seventy-fifty percent) did not agree to the accounting records with differences ranging from $27,632 to $139,044. Reporting errors could adversely affect future grant awards. An additional control(s) and/or additional procedure(s) should be implemented to help ensure accuracy of the reports.
FINDING 2023-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, and Procurement and Suspension and Debarment 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): PO 20011717 Pass-Through Entity: Indiana State Department of Health Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context The County Department of Health, a department within the County, was awarded the Health Issues and Challenges grant through the Indiana State Department of Health financed through the American Rescue Plan Act for the purpose of funding programs that focus on the improvement of chronic disease, specifically, elevated blood lead level reduction. The Health Issues and Challenges grant is a reimbursable grant, whereby the County received reimbursement on a per-case basis at a stated rate for Case Management and Environmental Investigation activities performed. The County Department of Health received federal receipts related to the grant in the amount of $130,479 during 2023. As part of sound management of the federal award, the County Department of Health was responsible for implementing a system of internal controls that would ensure compliance with the applicable requirements. The County Department of Health did not properly design or implement such a system. Receipts of the program were adequately identified through the use of an account number within the County Health Fund (285) in the County's ledger (ledger) which was unique to the Health Issues and Challenges grant receipts. However, the ledger did not adequately identify the expenditures of the grant program within the County Health Fund. Through inquiry with the County Department of Health employees and review of unit-prepared support of grant expenditures, we determined expenditures were made with grant funds during the audit period; however, we were unable to distinguish between the expenditures of the Health Issues and Challenges grant and all other activities of the County Department of Health in the County Health fund. Due to the lack of separate identification of expenditures in the financial records, we were not able to establish a population from which to audit the Health Issues and Challenges grant for compliance with the following compliance requirements of the program: Activities Allowed or Unallowed Allowable Costs/Cost Principles Period of Performance Procurement and Suspension and Debarment As such, the full award amount of $130,479, as reported on the Schedule of Expenditures of Federal Awards, was determined to be questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.300(b) states in part: "The non-Federal entity is responsible for complying with all requirements of the Federal award. . . ." 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. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. . . ." Cause The County Department of Health was unable to differentiate expenditures made from federal and non-federal funds within its ledger for the Heath Issues and Challenges grant. Effect Without the proper implementation of an effectively designed system of internal controls, a population of expenditures associated with the Health Issues and Challenges grant could not be determined. As such, the County Department of Health cannot ensure nor can we determine that expenditures of the grant were not unallowable, within the proper period, and adhered to established practices and policies. Questioned Costs We identified $130,479 in known questioned costs as noted in the Condition and Context. Recommendation We recommended that management of the County Department of Health establish a system of internal controls to ensure that grant award funds are adequately accounted for and tracked in such a manner as to determine the activity, receipts, and disbursements associated with the grant. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: Water and Waste Disposal System for Rual Communities - Reporting Federal Agency: Department of Agriculture Federal Program: Water and Waste Disposal System for Rural Communities Assistance Listings Number: 10.760 Federal Award Number and Year (or Other Identifying Number): CY 2023 Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The Town had not designed or implemented adequate internal controls and procedures to ensure that reports were prepared, accurate, and submitted in accordance with the applicable compliance requirements for the federal grant. The United States Department of Agriculture (USDA) requires the following reports be submitted annually: Statement of Budget, Income, and Equity (Form RD 442-2) Balance Sheet (Form RD 442-3) The Form RD 442-2 covers financial operations relating to the Town's water main replacement project and the Form RD 442-3 presents the financial status of the project. In both instances, a borrower may submit the financial data on other forms, provided the forms are in a similar format and signed and dated by the organization's official to certify the correctness of the information. Alternatively, an annual audit may be submitted in lieu of the forms. The Town was required to file each report, as noted above, during the audit period; however, the reports were not filed. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 19 TOWN OF LAFONTAINE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 7 CFR 1780.47 states in part: "Borrower accounting methods, management reporting and audits. . . . (e) Borrowers exempt from audits. All borrowers who are exempt from audits, will, within 60 days following the end of each fiscal year, furnish the RUS with annual financial statements, consisting of a verification of the organization's balance sheet and statement of income and expense by an appropriate official of the organization. Forms RD 442-2, 'Statement of Budget, Income and Equity,' and 442-3 may be used. (f) Management reports. These reports will furnish management with a means of evaluating prior decisions and serve as a basis for planning future operations and financial strategies. In those cases where revenues from multiple sources are pledged as security for an RUS loan, two reports will be required; one for the project being financed by RUS and one combining the entire operation of the borrower. In those cases where RUS loans are secured by general obligation bonds or assessments and the borrower combines revenues from all sources, one management report combining all such revenues is acceptable. The following management data will be submitted by the borrower to the processing office. These reports at a minimum will include a balance sheet and income and expense statement. . . . (2) Annual management reports. Prior to the beginning of each fiscal year the following will be submitted to the processing office. (If Form RD 442-2 is used as the annual management report, enter data in column three only of Schedule 1, and complete all of Schedule 2.) (i) Two copies of the management reports and proposed 'Annual Budget'. (ii) Financial information may be reported on Form RD 442-2 which includes Schedule 1, 'Statement of Budget, Income and Equity' and Schedule 2, 'Projected Cash Flow' or information in similar format. (iii) A copy of the rate schedule in effect at the time of submission. INDIANA STATE BOARD OF ACCOUNTS 20 TOWN OF LAFONTAINE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (g) Substitute for management reports. When RUS loans are secured by the general obligation of the public body or tax assessments which total 100 percent of the debt service requirements, the State program official may authorize an annual audit to substitute for other management reports if the audit is received within nine months after the end of the audit period." Cause The Town incorrectly assumed that the reports were filed by the engineering firm coordinating the grant. Effect Without the proper implementation of an effectively designed system of internal controls, the Town cannot ensure the required reports are filed with the awarding agency. As such, the USDA does not have accurate and current information to discern the financial status of the Town's project. Furthermore, noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the Town. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Town's management design and implement a system of internal controls to ensure that all required reports are filed. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
31 CFR § 35.4(c) requires, in part, recipients, during the period of performance, to provide the Secretary of the U.S. Department of Treasury periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. 2 CFR 1000.10 provides that, except for the deviations set forth elsewhere in this Part, the Department of Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards set forth at 2 CFR Part 200. 2 CFR 200.302(b) states, in part, that the financial management system of each non-Federal entity must provide for the 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. The County was required to submit a Project and Expenditure Report by October 31, 2023, to the U.S Department of the Treasury through the Treasury’s Portal. However, the lack of adequate control procedures in place for reporting resulted in the County omitting $2,000,851 in expenditures that were reported on their 2023 Schedule of Expenditures of Federal Awards from their 2023 third quarter Project and Expenditure Report. We also noted the County submitted the 2023 fourth quarter Project and Expenditure Report on March 7, 2024 instead of the required date of January 31 2024. The County should establish a proper control process over reporting to ensure the timely, complete, and accurate submission of the Project and Expenditure Reports. This will help reduce the risk of Treasury taking action against the County for failure to comply with programmatic requirements.
31 CFR § 35.4(c) requires, in part, recipients, during the period of performance, to provide the Secretary of the U.S. Department of Treasury periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. 2 CFR 1000.10 provides that, except for the deviations set forth elsewhere in this Part, the Department of Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards set forth at 2 CFR Part 200. 2 CFR 200.302(b) states, in part, that the financial management system of each non-Federal entity must provide for the 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. The County was required to submit a Project and Expenditure Report by October 31, 2023, to the U.S Department of the Treasury through the Treasury’s Portal. However, the lack of adequate control procedures in place for reporting resulted in the County omitting $2,000,851 in expenditures that were reported on their 2023 Schedule of Expenditures of Federal Awards from their 2023 third quarter Project and Expenditure Report. We also noted the County submitted the 2023 fourth quarter Project and Expenditure Report on March 7, 2024 instead of the required date of January 31 2024. The County should establish a proper control process over reporting to ensure the timely, complete, and accurate submission of the Project and Expenditure Reports. This will help reduce the risk of Treasury taking action against the County for failure to comply with programmatic requirements.
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.
Program Information: Assistance Listing #: 93.445 U.S. Department of Health and Human Services I.H.S. Water Tank Replacement Award Numbers: PH12-U35, RN21-15 Award Periods: 7/29/2021-7/29/2025 Criteria: Federal grant agreements and related regulations require recipients to submit “Progress/Performance Reports,” due quarterly. These reports must compare actual accomplishments to established goals and objectives, explain any variances, and summarize activities and milestones, in accordance with the terms set by the awarding agency and detailed in the grant agreement (CFR § 200.329) Condition/Context: The Tribe was unable to provide copies of the required quarterly progress/performance reports, and as a result, we could not verify whether the reports were submitted to the awarding agency as required. [ X ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: The Tribe did not retain copies of the required performance reports, and procedures for maintaining federal reporting documentation were not consistently followed. Turnover in management likely contributed to the lack of record retention. Effect: Because the Tribe did not maintain documentation, we were unable to determine whether required performance reports were submitted. Failure to submit required reports could lead to delayed payments from the grantor or denial of eligibility for future grants from the awarding agency. Questioned Costs: None noted. This is a reporting and documentation finding; no costs are questioned. Repeat Finding: No. Recommendation: We recommend the Tribe implement a formal process to track required federal reporting deadlines and ensure that copies of all submitted reports are maintained in the grant files. This may include establishing a reporting calendar, designating a responsible staff member to complete and retain the reports, and implementing a supervisory review to ensure compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
2 CFR 1000.10 provides that, except for the deviations set forth elsewhere in this Part, the Department of Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards set forth at 2 CFR Part 200. 2 CFR 200.329(c)(1) states that non-Federal entities must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. 31 CFR 35.4(c) requires recipients, in part, during the period of performance, to provide the Secretary of the U.S. Department of Treasury periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. The U.S. Department of Treasury provided supplementary information in its interim final rule on reporting requirements for State and Local Fiscal Recovery Funds for 31 CFR Part 35 and provided further guidance in its Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance. The Compliance and Reporting Guidance, part 2 states that counties with a population below 250,000 residents must submit a Project and Expenditure Report by April 30, 2022 and then annually thereafter through the end of the award period on December 31, 2026. The City was required to submit a Project and Expenditure Report by April 30, 2023, to the U.S. Department of the Treasury through the Treasury’s Portal. However, the lack of adequate control procedures in place for reporting resulted in the City failing to submit the required report. Also, the lack of adequate control procedures in place for reporting resulted in the City incorrectly reporting obligated and expense amounts in the report due April 30, 2024, for the activity of April 1, 2023 - March 31, 2024, the City over-reported current period expenditures and current period obligations in the amount of $230,388. Failure to have the proper controls in place to ensure the accurate submission of the Project and Expenditure Reports could result in Treasury taking action against the City for failure to comply with programmatic requirements. The City should implement and have controls in place to ensure the annual Project and Expenditure Reports are accurate.
2 CFR 1000.10 gives regulatory effect to the Department of Treasury for 2 CFR part 200.302. CFR 200.302(a) states, in part, the non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by 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 Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.302(b)(2) further states, in part, the financial management system of each non-Federal entity must provide for accurate, current, and complete disclosures of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. Additionally, the Ohio Department of Development (ODOD) Water and Wastewater Infrastructure Program Grant Agreement provides in Exhibit II that "Program reports must be submitted on a quarterly basis. Program reports must be submitted by close of business, on the second Friday at the end of each quarter.” Due to deficiencies in the City’s internal controls over reporting, the City did not submit quarterly program reports for any quarter in 2024. Failure to submit required quarterly program reports could result in the City not receiving the reimbursements that it is entitled to. The City should implement internal controls to ensure that reports are submitted by the required deadlines per reporting requirements.
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.
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.