Finding 2022-002 Program: AL No. 10.523 Centers of Excellence at 1890 Institutions Significant Deficiency and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes Condition: Management did not verify that its subrecipient?s were not suspended or debarred or otherwise excluded from participating in the transactions. Criteria: In accordance with 2 CFR ?200.303, the non-Federal entity must establish and maintain effective internal controls 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. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. Additionally, when entering into subaward transactions, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management(SAM)Exclusions maintained by the General Services Administration(GSA). Cause: Program personnel were unaware of the requirement included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: If subrecipients were not in compliance with Uniform Guidance, the Foundation would not identify the noncompliance timely. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation continue to improve the subrecipient monitoring controls its Federal programs and prepare and maintain a written plan to monitor its subrecipients. Auditee Response and Corrective Action Plan: Refer to management?s corrective action plans. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-002 Program: AL No. 10.523 Centers of Excellence at 1890 Institutions Significant Deficiency and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes Condition: Management did not verify that its subrecipient?s were not suspended or debarred or otherwise excluded from participating in the transactions. Criteria: In accordance with 2 CFR ?200.303, the non-Federal entity must establish and maintain effective internal controls 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. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. Additionally, when entering into subaward transactions, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management(SAM)Exclusions maintained by the General Services Administration(GSA). Cause: Program personnel were unaware of the requirement included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: If subrecipients were not in compliance with Uniform Guidance, the Foundation would not identify the noncompliance timely. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation continue to improve the subrecipient monitoring controls its Federal programs and prepare and maintain a written plan to monitor its subrecipients. Auditee Response and Corrective Action Plan: Refer to management?s corrective action plans. Auditor?s Conclusion: Finding remains as stated.
2022-004 Subrecipient Monitoring Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Effort Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Award Period: 2022 and 2021 Pass-through Entity: n/a Questioned Costs: None Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The requirements for subrecipient monitoring for the subaward are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of the award. The County must do the following: (1) Review the pass-through entity (PTE’s) subrecipient monitoring policies and procedures to gain an understanding of the PTE’s process to identify subawards, evaluate risk of noncompliance, and perform monitoring procedures based upon identified risks. (2) Review subaward documents including the terms and conditions of the subaward to ascertain if, at the time of subaward (or subsequent subaward modification), the PTE made the subrecipient aware of the award information required by 2 CFR section 200.331(a) sufficient for the PTE to comply with federal statutes, regulations, and the terms and conditions of the award. (3) Review the PTE’s documentation of monitoring the subaward and consider if the PTE’s monitoring provided reasonable assurance that the subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. (4) Ascertain if the PTE verified that subrecipients expected to be audited as required by 2 CFR Part 200, Subpart F, met this requirement (2 CFR section 200.331(f)). This verification may be performed as part of the required monitoring under 2 CFR section 200.331(d)(2) to ensure that the subrecipient takes timely and appropriate action on deficiencies detected though audits. Condition: During our testing, it was noted the County did not have adequate controls designed to ensure that subrecipient monitoring requirements were being met. Context: Of the 3 subrecipients tested, all 3 did not included signed, formal agreements between the County and subrecipients. Cause: The County has not designed and implemented internal controls to ensure compliance with subrecipient monitoring requirements. Effect: The County was not communicating the required information to subrecipients through a formal agreement. Recommendation: We recommend the County implement internal control(s) to ensure that required subrecipient monitoring through formal agreements is completed. Repeat Finding: No Views of Responsible Officials: There is no disagreement with the audit finding.
Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-005 SUBRECIPIENT MONITORING Material Weakness Criteria The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of federal awards should be following federal regulations, the terms of the federal contract, and any additional requirements specified by the auditee's policies and procedures. Specifically, the monitoring criteria should include, but not be limited to, the following: • Subrecipient Risk Assessment • Financial Monitoring • Compliance Monitoring • Reporting and Documentation Condition The auditee failed to comply with federal regulations requiring the monitoring of subrecipients for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring the activities of subrecipients to ensure that they comply with applicable laws, regulations, and the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its 2022 subrecipients until 2024. During the year ended December 31, 2022, CUAHSI had $252,550 in amounts paid to subrecipients. Based on our testing of amounts paid to subrecipients, no amounts were identified as unallowable.Material Weakness Cause & Context CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring. There was no audit evidence of CUAHSI following the policy and monitoring that the subrecipient was using the funding as prescribed during the year ended December 31, 2022. Effect CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of funds. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-005. Recommendation The auditor recommends that management review the requirements documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities) and develops and implements procedures to adhere to such requirements. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-005 SUBRECIPIENT MONITORING Material Weakness Criteria The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of federal awards should be following federal regulations, the terms of the federal contract, and any additional requirements specified by the auditee's policies and procedures. Specifically, the monitoring criteria should include, but not be limited to, the following: • Subrecipient Risk Assessment • Financial Monitoring • Compliance Monitoring • Reporting and Documentation Condition The auditee failed to comply with federal regulations requiring the monitoring of subrecipients for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring the activities of subrecipients to ensure that they comply with applicable laws, regulations, and the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its 2022 subrecipients until 2024. During the year ended December 31, 2022, CUAHSI had $252,550 in amounts paid to subrecipients. Based on our testing of amounts paid to subrecipients, no amounts were identified as unallowable.Material Weakness Cause & Context CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring. There was no audit evidence of CUAHSI following the policy and monitoring that the subrecipient was using the funding as prescribed during the year ended December 31, 2022. Effect CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of funds. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-005. Recommendation The auditor recommends that management review the requirements documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities) and develops and implements procedures to adhere to such requirements. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-005 SUBRECIPIENT MONITORING Material Weakness Criteria The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of federal awards should be following federal regulations, the terms of the federal contract, and any additional requirements specified by the auditee's policies and procedures. Specifically, the monitoring criteria should include, but not be limited to, the following: • Subrecipient Risk Assessment • Financial Monitoring • Compliance Monitoring • Reporting and Documentation Condition The auditee failed to comply with federal regulations requiring the monitoring of subrecipients for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring the activities of subrecipients to ensure that they comply with applicable laws, regulations, and the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its 2022 subrecipients until 2024. During the year ended December 31, 2022, CUAHSI had $252,550 in amounts paid to subrecipients. Based on our testing of amounts paid to subrecipients, no amounts were identified as unallowable.Material Weakness Cause & Context CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring. There was no audit evidence of CUAHSI following the policy and monitoring that the subrecipient was using the funding as prescribed during the year ended December 31, 2022. Effect CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of funds. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-005. Recommendation The auditor recommends that management review the requirements documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities) and develops and implements procedures to adhere to such requirements. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-005 SUBRECIPIENT MONITORING Material Weakness Criteria The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of federal awards should be following federal regulations, the terms of the federal contract, and any additional requirements specified by the auditee's policies and procedures. Specifically, the monitoring criteria should include, but not be limited to, the following: • Subrecipient Risk Assessment • Financial Monitoring • Compliance Monitoring • Reporting and Documentation Condition The auditee failed to comply with federal regulations requiring the monitoring of subrecipients for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring the activities of subrecipients to ensure that they comply with applicable laws, regulations, and the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its 2022 subrecipients until 2024. During the year ended December 31, 2022, CUAHSI had $252,550 in amounts paid to subrecipients. Based on our testing of amounts paid to subrecipients, no amounts were identified as unallowable.Material Weakness Cause & Context CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring. There was no audit evidence of CUAHSI following the policy and monitoring that the subrecipient was using the funding as prescribed during the year ended December 31, 2022. Effect CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of funds. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-005. Recommendation The auditor recommends that management review the requirements documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities) and develops and implements procedures to adhere to such requirements. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
Finding 2022-002 Program: AL No. 10.523 Centers of Excellence at 1890 Institutions Significant Deficiency and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes Condition: Management did not verify that its subrecipient?s were not suspended or debarred or otherwise excluded from participating in the transactions. Criteria: In accordance with 2 CFR ?200.303, the non-Federal entity must establish and maintain effective internal controls 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. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. Additionally, when entering into subaward transactions, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management(SAM)Exclusions maintained by the General Services Administration(GSA). Cause: Program personnel were unaware of the requirement included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: If subrecipients were not in compliance with Uniform Guidance, the Foundation would not identify the noncompliance timely. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation continue to improve the subrecipient monitoring controls its Federal programs and prepare and maintain a written plan to monitor its subrecipients. Auditee Response and Corrective Action Plan: Refer to management?s corrective action plans. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-002 Program: AL No. 10.523 Centers of Excellence at 1890 Institutions Significant Deficiency and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes Condition: Management did not verify that its subrecipient?s were not suspended or debarred or otherwise excluded from participating in the transactions. Criteria: In accordance with 2 CFR ?200.303, the non-Federal entity must establish and maintain effective internal controls 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. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. Additionally, when entering into subaward transactions, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management(SAM)Exclusions maintained by the General Services Administration(GSA). Cause: Program personnel were unaware of the requirement included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: If subrecipients were not in compliance with Uniform Guidance, the Foundation would not identify the noncompliance timely. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation continue to improve the subrecipient monitoring controls its Federal programs and prepare and maintain a written plan to monitor its subrecipients. Auditee Response and Corrective Action Plan: Refer to management?s corrective action plans. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-002 Program: AL No. 10.523 Centers of Excellence at 1890 Institutions Significant Deficiency and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes Condition: Management did not verify that its subrecipient?s were not suspended or debarred or otherwise excluded from participating in the transactions. Criteria: In accordance with 2 CFR ?200.303, the non-Federal entity must establish and maintain effective internal controls 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. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. Additionally, when entering into subaward transactions, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management(SAM)Exclusions maintained by the General Services Administration(GSA). Cause: Program personnel were unaware of the requirement included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: If subrecipients were not in compliance with Uniform Guidance, the Foundation would not identify the noncompliance timely. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation continue to improve the subrecipient monitoring controls its Federal programs and prepare and maintain a written plan to monitor its subrecipients. Auditee Response and Corrective Action Plan: Refer to management?s corrective action plans. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-002 Program: AL No. 10.523 Centers of Excellence at 1890 Institutions Significant Deficiency and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes Condition: Management did not verify that its subrecipient?s were not suspended or debarred or otherwise excluded from participating in the transactions. Criteria: In accordance with 2 CFR ?200.303, the non-Federal entity must establish and maintain effective internal controls 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. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. Additionally, when entering into subaward transactions, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management(SAM)Exclusions maintained by the General Services Administration(GSA). Cause: Program personnel were unaware of the requirement included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: If subrecipients were not in compliance with Uniform Guidance, the Foundation would not identify the noncompliance timely. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation continue to improve the subrecipient monitoring controls its Federal programs and prepare and maintain a written plan to monitor its subrecipients. Auditee Response and Corrective Action Plan: Refer to management?s corrective action plans. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-002 Program: AL No. 10.523 Centers of Excellence at 1890 Institutions Significant Deficiency and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes Condition: Management did not verify that its subrecipient?s were not suspended or debarred or otherwise excluded from participating in the transactions. Criteria: In accordance with 2 CFR ?200.303, the non-Federal entity must establish and maintain effective internal controls 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. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. Additionally, when entering into subaward transactions, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management(SAM)Exclusions maintained by the General Services Administration(GSA). Cause: Program personnel were unaware of the requirement included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: If subrecipients were not in compliance with Uniform Guidance, the Foundation would not identify the noncompliance timely. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation continue to improve the subrecipient monitoring controls its Federal programs and prepare and maintain a written plan to monitor its subrecipients. Auditee Response and Corrective Action Plan: Refer to management?s corrective action plans. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-002 Program: AL No. 10.523 Centers of Excellence at 1890 Institutions Significant Deficiency and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes Condition: Management did not verify that its subrecipient?s were not suspended or debarred or otherwise excluded from participating in the transactions. Criteria: In accordance with 2 CFR ?200.303, the non-Federal entity must establish and maintain effective internal controls 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. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. Additionally, when entering into subaward transactions, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management(SAM)Exclusions maintained by the General Services Administration(GSA). Cause: Program personnel were unaware of the requirement included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: If subrecipients were not in compliance with Uniform Guidance, the Foundation would not identify the noncompliance timely. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation continue to improve the subrecipient monitoring controls its Federal programs and prepare and maintain a written plan to monitor its subrecipients. Auditee Response and Corrective Action Plan: Refer to management?s corrective action plans. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-002 Program: AL No. 10.523 Centers of Excellence at 1890 Institutions Significant Deficiency and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes Condition: Management did not verify that its subrecipient?s were not suspended or debarred or otherwise excluded from participating in the transactions. Criteria: In accordance with 2 CFR ?200.303, the non-Federal entity must establish and maintain effective internal controls 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. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. Additionally, when entering into subaward transactions, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management(SAM)Exclusions maintained by the General Services Administration(GSA). Cause: Program personnel were unaware of the requirement included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: If subrecipients were not in compliance with Uniform Guidance, the Foundation would not identify the noncompliance timely. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation continue to improve the subrecipient monitoring controls its Federal programs and prepare and maintain a written plan to monitor its subrecipients. Auditee Response and Corrective Action Plan: Refer to management?s corrective action plans. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-002 Program: AL No. 10.523 Centers of Excellence at 1890 Institutions Significant Deficiency and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes Condition: Management did not verify that its subrecipient?s were not suspended or debarred or otherwise excluded from participating in the transactions. Criteria: In accordance with 2 CFR ?200.303, the non-Federal entity must establish and maintain effective internal controls 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. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. Additionally, when entering into subaward transactions, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management(SAM)Exclusions maintained by the General Services Administration(GSA). Cause: Program personnel were unaware of the requirement included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: If subrecipients were not in compliance with Uniform Guidance, the Foundation would not identify the noncompliance timely. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation continue to improve the subrecipient monitoring controls its Federal programs and prepare and maintain a written plan to monitor its subrecipients. Auditee Response and Corrective Action Plan: Refer to management?s corrective action plans. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-002 Program: AL No. 10.523 Centers of Excellence at 1890 Institutions Significant Deficiency and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes Condition: Management did not verify that its subrecipient?s were not suspended or debarred or otherwise excluded from participating in the transactions. Criteria: In accordance with 2 CFR ?200.303, the non-Federal entity must establish and maintain effective internal controls 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. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. Additionally, when entering into subaward transactions, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management(SAM)Exclusions maintained by the General Services Administration(GSA). Cause: Program personnel were unaware of the requirement included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: If subrecipients were not in compliance with Uniform Guidance, the Foundation would not identify the noncompliance timely. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation continue to improve the subrecipient monitoring controls its Federal programs and prepare and maintain a written plan to monitor its subrecipients. Auditee Response and Corrective Action Plan: Refer to management?s corrective action plans. Auditor?s Conclusion: Finding remains as stated.
2022-004 Subrecipient Monitoring Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Effort Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Award Period: 2022 and 2021 Pass-through Entity: n/a Questioned Costs: None Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The requirements for subrecipient monitoring for the subaward are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of the award. The County must do the following: (1) Review the pass-through entity (PTE’s) subrecipient monitoring policies and procedures to gain an understanding of the PTE’s process to identify subawards, evaluate risk of noncompliance, and perform monitoring procedures based upon identified risks. (2) Review subaward documents including the terms and conditions of the subaward to ascertain if, at the time of subaward (or subsequent subaward modification), the PTE made the subrecipient aware of the award information required by 2 CFR section 200.331(a) sufficient for the PTE to comply with federal statutes, regulations, and the terms and conditions of the award. (3) Review the PTE’s documentation of monitoring the subaward and consider if the PTE’s monitoring provided reasonable assurance that the subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. (4) Ascertain if the PTE verified that subrecipients expected to be audited as required by 2 CFR Part 200, Subpart F, met this requirement (2 CFR section 200.331(f)). This verification may be performed as part of the required monitoring under 2 CFR section 200.331(d)(2) to ensure that the subrecipient takes timely and appropriate action on deficiencies detected though audits. Condition: During our testing, it was noted the County did not have adequate controls designed to ensure that subrecipient monitoring requirements were being met. Context: Of the 3 subrecipients tested, all 3 did not included signed, formal agreements between the County and subrecipients. Cause: The County has not designed and implemented internal controls to ensure compliance with subrecipient monitoring requirements. Effect: The County was not communicating the required information to subrecipients through a formal agreement. Recommendation: We recommend the County implement internal control(s) to ensure that required subrecipient monitoring through formal agreements is completed. Repeat Finding: No Views of Responsible Officials: There is no disagreement with the audit finding.
Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-005 SUBRECIPIENT MONITORING Material Weakness Criteria The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of federal awards should be following federal regulations, the terms of the federal contract, and any additional requirements specified by the auditee's policies and procedures. Specifically, the monitoring criteria should include, but not be limited to, the following: • Subrecipient Risk Assessment • Financial Monitoring • Compliance Monitoring • Reporting and Documentation Condition The auditee failed to comply with federal regulations requiring the monitoring of subrecipients for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring the activities of subrecipients to ensure that they comply with applicable laws, regulations, and the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its 2022 subrecipients until 2024. During the year ended December 31, 2022, CUAHSI had $252,550 in amounts paid to subrecipients. Based on our testing of amounts paid to subrecipients, no amounts were identified as unallowable.Material Weakness Cause & Context CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring. There was no audit evidence of CUAHSI following the policy and monitoring that the subrecipient was using the funding as prescribed during the year ended December 31, 2022. Effect CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of funds. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-005. Recommendation The auditor recommends that management review the requirements documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities) and develops and implements procedures to adhere to such requirements. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-005 SUBRECIPIENT MONITORING Material Weakness Criteria The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of federal awards should be following federal regulations, the terms of the federal contract, and any additional requirements specified by the auditee's policies and procedures. Specifically, the monitoring criteria should include, but not be limited to, the following: • Subrecipient Risk Assessment • Financial Monitoring • Compliance Monitoring • Reporting and Documentation Condition The auditee failed to comply with federal regulations requiring the monitoring of subrecipients for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring the activities of subrecipients to ensure that they comply with applicable laws, regulations, and the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its 2022 subrecipients until 2024. During the year ended December 31, 2022, CUAHSI had $252,550 in amounts paid to subrecipients. Based on our testing of amounts paid to subrecipients, no amounts were identified as unallowable.Material Weakness Cause & Context CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring. There was no audit evidence of CUAHSI following the policy and monitoring that the subrecipient was using the funding as prescribed during the year ended December 31, 2022. Effect CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of funds. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-005. Recommendation The auditor recommends that management review the requirements documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities) and develops and implements procedures to adhere to such requirements. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-005 SUBRECIPIENT MONITORING Material Weakness Criteria The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of federal awards should be following federal regulations, the terms of the federal contract, and any additional requirements specified by the auditee's policies and procedures. Specifically, the monitoring criteria should include, but not be limited to, the following: • Subrecipient Risk Assessment • Financial Monitoring • Compliance Monitoring • Reporting and Documentation Condition The auditee failed to comply with federal regulations requiring the monitoring of subrecipients for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring the activities of subrecipients to ensure that they comply with applicable laws, regulations, and the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its 2022 subrecipients until 2024. During the year ended December 31, 2022, CUAHSI had $252,550 in amounts paid to subrecipients. Based on our testing of amounts paid to subrecipients, no amounts were identified as unallowable.Material Weakness Cause & Context CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring. There was no audit evidence of CUAHSI following the policy and monitoring that the subrecipient was using the funding as prescribed during the year ended December 31, 2022. Effect CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of funds. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-005. Recommendation The auditor recommends that management review the requirements documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities) and develops and implements procedures to adhere to such requirements. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-005 SUBRECIPIENT MONITORING Material Weakness Criteria The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of federal awards should be following federal regulations, the terms of the federal contract, and any additional requirements specified by the auditee's policies and procedures. Specifically, the monitoring criteria should include, but not be limited to, the following: • Subrecipient Risk Assessment • Financial Monitoring • Compliance Monitoring • Reporting and Documentation Condition The auditee failed to comply with federal regulations requiring the monitoring of subrecipients for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring the activities of subrecipients to ensure that they comply with applicable laws, regulations, and the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its 2022 subrecipients until 2024. During the year ended December 31, 2022, CUAHSI had $252,550 in amounts paid to subrecipients. Based on our testing of amounts paid to subrecipients, no amounts were identified as unallowable.Material Weakness Cause & Context CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring. There was no audit evidence of CUAHSI following the policy and monitoring that the subrecipient was using the funding as prescribed during the year ended December 31, 2022. Effect CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of funds. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-005. Recommendation The auditor recommends that management review the requirements documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities) and develops and implements procedures to adhere to such requirements. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, period of performance, reporting, and special tests and provisions ? wage rate requirements. The related compliance requirements are set in 24 CFR Part 570 Subpart D and sections 570.200 through .710, the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the April 30, 2021 Quick Guide, CDBG-CV PPR Tieback Flexibilities, Title I of the Housing Community Development Act (HCDA) of 1974, as amended (Pub. L. No. 93-383) (42 USC 5301), 2 CFR Part 200, Subpart E, Appendices III-V11, and sections 200.330, .331, and .501(h), 31 USC 1552, Section III.B.7 of CDBG-CV Notice, Section 110(a) of the HCD Act, federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of financial reports to ensure compliance with allowable costs, cost principles, period of performance, and reporting requirements were not documented in a manner that is reperformable. Weekly payroll reports were not reviewed as part of the special tests and provisions ? wage rate requirements compliance requirement, resulting in material noncompliance. Cause: Internal controls over financial reports were not evidenced with clear documentation. Effect: Financial reports may not be accurate, allowable costs, cost principles, and period of performance compliance requirements may not be met due to lack of reperformable internal controls. Wage rate requirements were not complied with. Recommendation: We recommend that the City ensure wage rate requirement compliance is prioritized when applicable. We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, period of performance, reporting, and special tests and provisions ? wage rate requirements. The related compliance requirements are set in 24 CFR Part 570 Subpart D and sections 570.200 through .710, the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the April 30, 2021 Quick Guide, CDBG-CV PPR Tieback Flexibilities, Title I of the Housing Community Development Act (HCDA) of 1974, as amended (Pub. L. No. 93-383) (42 USC 5301), 2 CFR Part 200, Subpart E, Appendices III-V11, and sections 200.330, .331, and .501(h), 31 USC 1552, Section III.B.7 of CDBG-CV Notice, Section 110(a) of the HCD Act, federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of financial reports to ensure compliance with allowable costs, cost principles, period of performance, and reporting requirements were not documented in a manner that is reperformable. Weekly payroll reports were not reviewed as part of the special tests and provisions ? wage rate requirements compliance requirement, resulting in material noncompliance. Cause: Internal controls over financial reports were not evidenced with clear documentation. Effect: Financial reports may not be accurate, allowable costs, cost principles, and period of performance compliance requirements may not be met due to lack of reperformable internal controls. Wage rate requirements were not complied with. Recommendation: We recommend that the City ensure wage rate requirement compliance is prioritized when applicable. We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, and matching. The related compliance requirements are set in 2 CFR sections 200.330, .331, .501(h), .514(c), and subpart E, 24 CFR Part 576, federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of monthly subrecipient reports to ensure compliance with allowable costs, cost principles, and matching requirements were not documented in a manner that is reperformable. Timesheet approvals were not documented in all instances to ensure compliance with allowable costs, cost principles. Cause: Internal controls over monthly subrecipient report review for allowable costs, cost principles, and matching compliance requirements and timesheet reviews and approvals were not evidenced with clear documentation. Effect: Subrecipients may not have met required matching compliance requirements. Time could be charged to the grant that is not allowable. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, and matching. The related compliance requirements are set in 2 CFR sections 200.330, .331, .501(h), .514(c), and subpart E, 24 CFR Part 576, federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of monthly subrecipient reports to ensure compliance with allowable costs, cost principles, and matching requirements were not documented in a manner that is reperformable. Timesheet approvals were not documented in all instances to ensure compliance with allowable costs, cost principles. Cause: Internal controls over monthly subrecipient report review for allowable costs, cost principles, and matching compliance requirements and timesheet reviews and approvals were not evidenced with clear documentation. Effect: Subrecipients may not have met required matching compliance requirements. Time could be charged to the grant that is not allowable. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, cash management, period of performance, matching, and reporting. The related compliance requirements are set in 24 CFR Part 570 Subparts D and E, Appendices III-V11, and sections 200.330, .331, and .501(h), the Omnibus Crime Control and Safe Streets Act of 1968 as amended by the Violent Crime Control and Law Enforcement Act of 1994, Title I, Part Q, Pub. L. No. 103-322, 34 USC 10381 et seq., federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of financial and drawdown reports to ensure compliance with reporting requirements which also covers allowable costs, cost principles, cash management, period of performance, and matching requirements were not documented in a manner that is reperformable. No internal controls were identified related to review of progress reports to ensure compliance with reporting requirements. Cause: Internal controls over financial, drawdown, and progress reports were not evidenced with clear documentation. Effect: Financial reports may not be accurate; allowable costs, cost principles, cash management, period of performance, matching, and reporting compliance requirements may not be met due to lack of reperformable internal controls. Progress reports may not be accurate. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, cash management, period of performance, matching, and reporting. The related compliance requirements are set in 24 CFR Part 570 Subparts D and E, Appendices III-V11, and sections 200.330, .331, and .501(h), the Omnibus Crime Control and Safe Streets Act of 1968 as amended by the Violent Crime Control and Law Enforcement Act of 1994, Title I, Part Q, Pub. L. No. 103-322, 34 USC 10381 et seq., federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of financial and drawdown reports to ensure compliance with reporting requirements which also covers allowable costs, cost principles, cash management, period of performance, and matching requirements were not documented in a manner that is reperformable. No internal controls were identified related to review of progress reports to ensure compliance with reporting requirements. Cause: Internal controls over financial, drawdown, and progress reports were not evidenced with clear documentation. Effect: Financial reports may not be accurate; allowable costs, cost principles, cash management, period of performance, matching, and reporting compliance requirements may not be met due to lack of reperformable internal controls. Progress reports may not be accurate. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.332 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, beneficiary eligibility, period of performance, reporting, subrecipient monitoring, and special tests and provisions. The related compliance requirements are set in Section 501 of Division N of the Consolidated Appropriations Act, 2021, 2 CFR Part 200, Subpart E, Appendices III-V11, and sections 200.330, .331, and .501(h), federal awarding agency regulations, and the terms and conditions of the award. Condition: Subrecipient monitoring controls related to periodic subrecipient reports and the final subrecipient expenditure reports, financial reporting, period of performance, and special tests and provisions for funding reallocations were not documented in a manner that is reperformable. Cause: Control activities were performed informally and without clear documentation. Effect: Individuals who are not eligible to receive the services funded by this grant may incorrectly be served by the subrecipient entities, allowable costs or cost principles may not have been followed by subrecipient entities, or subrecipients may not have been properly monitored for other compliance requirements. Expenditures could be made outside of the period of performance, amounts in the financial reports could be incorrect, funding reallocation requirements could be missed. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, cash management, matching/level of effort, and reporting. The related compliance requirements are set in 24 CFR Part 570 Subparts D and E, Appendices III-V11, and sections 200.330, .331, and .501(h), Section 34 of the Federal Fire Prevention and Control Act of 1974, Pub. L. No. 93-498, as amended (15 USC Sec. 2229a) and Section 4013 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2, federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of drawdown reports to ensure compliance with reporting requirements which also covers allowable costs, cost principles, cash management, and matching requirements were not documented in a manner that is reperformable. No internal controls were identified related to review of progress reports to ensure compliance with reporting requirements. No internal controls were identified related to the level of effort requirement. Cause: Internal controls related to review of drawdown reports, progress reports, and level of effort were not evidenced with clear documentation. Effect: Financial reports may not be accurate; allowable costs, cost principles, cash management, level of effort, matching, and reporting compliance requirements may not be met due to lack of reperformable internal controls. Progress reports may not be accurate. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, cash management, matching/level of effort, and reporting. The related compliance requirements are set in 24 CFR Part 570 Subparts D and E, Appendices III-V11, and sections 200.330, .331, and .501(h), Section 34 of the Federal Fire Prevention and Control Act of 1974, Pub. L. No. 93-498, as amended (15 USC Sec. 2229a) and Section 4013 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2, federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of drawdown reports to ensure compliance with reporting requirements which also covers allowable costs, cost principles, cash management, and matching requirements were not documented in a manner that is reperformable. No internal controls were identified related to review of progress reports to ensure compliance with reporting requirements. No internal controls were identified related to the level of effort requirement. Cause: Internal controls related to review of drawdown reports, progress reports, and level of effort were not evidenced with clear documentation. Effect: Financial reports may not be accurate; allowable costs, cost principles, cash management, level of effort, matching, and reporting compliance requirements may not be met due to lack of reperformable internal controls. Progress reports may not be accurate. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, period of performance, reporting, and special tests and provisions ? wage rate requirements. The related compliance requirements are set in 24 CFR Part 570 Subpart D and sections 570.200 through .710, the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the April 30, 2021 Quick Guide, CDBG-CV PPR Tieback Flexibilities, Title I of the Housing Community Development Act (HCDA) of 1974, as amended (Pub. L. No. 93-383) (42 USC 5301), 2 CFR Part 200, Subpart E, Appendices III-V11, and sections 200.330, .331, and .501(h), 31 USC 1552, Section III.B.7 of CDBG-CV Notice, Section 110(a) of the HCD Act, federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of financial reports to ensure compliance with allowable costs, cost principles, period of performance, and reporting requirements were not documented in a manner that is reperformable. Weekly payroll reports were not reviewed as part of the special tests and provisions ? wage rate requirements compliance requirement, resulting in material noncompliance. Cause: Internal controls over financial reports were not evidenced with clear documentation. Effect: Financial reports may not be accurate, allowable costs, cost principles, and period of performance compliance requirements may not be met due to lack of reperformable internal controls. Wage rate requirements were not complied with. Recommendation: We recommend that the City ensure wage rate requirement compliance is prioritized when applicable. We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, period of performance, reporting, and special tests and provisions ? wage rate requirements. The related compliance requirements are set in 24 CFR Part 570 Subpart D and sections 570.200 through .710, the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the April 30, 2021 Quick Guide, CDBG-CV PPR Tieback Flexibilities, Title I of the Housing Community Development Act (HCDA) of 1974, as amended (Pub. L. No. 93-383) (42 USC 5301), 2 CFR Part 200, Subpart E, Appendices III-V11, and sections 200.330, .331, and .501(h), 31 USC 1552, Section III.B.7 of CDBG-CV Notice, Section 110(a) of the HCD Act, federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of financial reports to ensure compliance with allowable costs, cost principles, period of performance, and reporting requirements were not documented in a manner that is reperformable. Weekly payroll reports were not reviewed as part of the special tests and provisions ? wage rate requirements compliance requirement, resulting in material noncompliance. Cause: Internal controls over financial reports were not evidenced with clear documentation. Effect: Financial reports may not be accurate, allowable costs, cost principles, and period of performance compliance requirements may not be met due to lack of reperformable internal controls. Wage rate requirements were not complied with. Recommendation: We recommend that the City ensure wage rate requirement compliance is prioritized when applicable. We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, and matching. The related compliance requirements are set in 2 CFR sections 200.330, .331, .501(h), .514(c), and subpart E, 24 CFR Part 576, federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of monthly subrecipient reports to ensure compliance with allowable costs, cost principles, and matching requirements were not documented in a manner that is reperformable. Timesheet approvals were not documented in all instances to ensure compliance with allowable costs, cost principles. Cause: Internal controls over monthly subrecipient report review for allowable costs, cost principles, and matching compliance requirements and timesheet reviews and approvals were not evidenced with clear documentation. Effect: Subrecipients may not have met required matching compliance requirements. Time could be charged to the grant that is not allowable. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, and matching. The related compliance requirements are set in 2 CFR sections 200.330, .331, .501(h), .514(c), and subpart E, 24 CFR Part 576, federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of monthly subrecipient reports to ensure compliance with allowable costs, cost principles, and matching requirements were not documented in a manner that is reperformable. Timesheet approvals were not documented in all instances to ensure compliance with allowable costs, cost principles. Cause: Internal controls over monthly subrecipient report review for allowable costs, cost principles, and matching compliance requirements and timesheet reviews and approvals were not evidenced with clear documentation. Effect: Subrecipients may not have met required matching compliance requirements. Time could be charged to the grant that is not allowable. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, cash management, period of performance, matching, and reporting. The related compliance requirements are set in 24 CFR Part 570 Subparts D and E, Appendices III-V11, and sections 200.330, .331, and .501(h), the Omnibus Crime Control and Safe Streets Act of 1968 as amended by the Violent Crime Control and Law Enforcement Act of 1994, Title I, Part Q, Pub. L. No. 103-322, 34 USC 10381 et seq., federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of financial and drawdown reports to ensure compliance with reporting requirements which also covers allowable costs, cost principles, cash management, period of performance, and matching requirements were not documented in a manner that is reperformable. No internal controls were identified related to review of progress reports to ensure compliance with reporting requirements. Cause: Internal controls over financial, drawdown, and progress reports were not evidenced with clear documentation. Effect: Financial reports may not be accurate; allowable costs, cost principles, cash management, period of performance, matching, and reporting compliance requirements may not be met due to lack of reperformable internal controls. Progress reports may not be accurate. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.