Finding 2021-008 Noncompliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Period of Performance Finding 2021-009 Noncompliance with Eligibility Compliance Requirements: • Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Per 2 CFR 200.303, the auditee must establish and maintain effective internal control over federal awards and per 2 CFR 200.403, costs must be necessary, reasonable, allocable, and authorized consistent with policies and procedures that apply uniformly to both federally financed and other activities. The costs must also occur during the proper grant period of performance. • Eligibility – Per 2 CFR 200.303 and 2 CFR 200.331, the auditee must establish and maintain internal controls to ensure that only eligible individuals, organizations, or activities receive assistance under federal awards. Criteria: An effective system of internal control over compliance requires that expenditures charged to federal awards be supported by adequate documentation to demonstrate that: • Costs are necessary, reasonable, allocable, and allowable under program requirements. • Expenditures are for activities permitted under the terms and conditions of the award and recorded properly. • Participants or beneficiaries meet eligibility requirements. Condition: During our testing of expenditures and program activity for the federal program, we identified multiple instances in which transactions lacked adequate supporting documentation to demonstrate compliance with the above requirements. Specifically: • SSVF – ALN 64.033: Of the sixty expense transactions tested over SSVF, four did not have corresponding support or documentation to verify they were allowable activities, allowable costs, and recognized in the correct period. Specifically, invoices, purchase orders, or timesheets were missing, incomplete, or did not adequately substantiate the expenditures charged to the federal award. During testing of SSVF participant files, we noted that 13 out of 60 client files could not be located or were missing required documentation within their file, which did not allow us to properly determine if these participants were in fact eligible to be served under this program. Cause: The lack of documentation was primarily due to inadequate internal control procedures over record retention and verification. Additionally, there was significant turnover which contributed to inconsistent documentation practices. Effect or Potential Effect: Without sufficient supporting documentation, the Organization cannot demonstrate that: • Expenditures were for allowable activities. • Costs charged were necessary, reasonable, and allocable and recorded properly. • Participants or beneficiaries met eligibility requirements. Questioned costs: Due to insufficient documentation, the amount of questioned costs could not be determined. Recommendation: We recommend the Organization strengthen its compliance-related internal controls by: • Requiring standardized documentation to support compliance with each requirement. • Implementing periodic reviews of documentation completeness before charging costs to federal awards. • Providing training to staff responsible for grant management on compliance and record retention requirements. • Retain all documentation related to federal awards in a central location. Views of responsible officials: Management agrees with the finding and the recommendation. Corrective action plan: See Management’s Corrective Action Plan (Unaudited).
Finding 2021-008 Noncompliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Period of Performance Finding 2021-009 Noncompliance with Eligibility Compliance Requirements: • Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Per 2 CFR 200.303, the auditee must establish and maintain effective internal control over federal awards and per 2 CFR 200.403, costs must be necessary, reasonable, allocable, and authorized consistent with policies and procedures that apply uniformly to both federally financed and other activities. The costs must also occur during the proper grant period of performance. • Eligibility – Per 2 CFR 200.303 and 2 CFR 200.331, the auditee must establish and maintain internal controls to ensure that only eligible individuals, organizations, or activities receive assistance under federal awards. Criteria: An effective system of internal control over compliance requires that expenditures charged to federal awards be supported by adequate documentation to demonstrate that: • Costs are necessary, reasonable, allocable, and allowable under program requirements. • Expenditures are for activities permitted under the terms and conditions of the award and recorded properly. • Participants or beneficiaries meet eligibility requirements. Condition: During our testing of expenditures and program activity for the federal program, we identified multiple instances in which transactions lacked adequate supporting documentation to demonstrate compliance with the above requirements. Specifically: • SSVF – ALN 64.033: Of the sixty expense transactions tested over SSVF, four did not have corresponding support or documentation to verify they were allowable activities, allowable costs, and recognized in the correct period. Specifically, invoices, purchase orders, or timesheets were missing, incomplete, or did not adequately substantiate the expenditures charged to the federal award. During testing of SSVF participant files, we noted that 13 out of 60 client files could not be located or were missing required documentation within their file, which did not allow us to properly determine if these participants were in fact eligible to be served under this program. Cause: The lack of documentation was primarily due to inadequate internal control procedures over record retention and verification. Additionally, there was significant turnover which contributed to inconsistent documentation practices. Effect or Potential Effect: Without sufficient supporting documentation, the Organization cannot demonstrate that: • Expenditures were for allowable activities. • Costs charged were necessary, reasonable, and allocable and recorded properly. • Participants or beneficiaries met eligibility requirements. Questioned costs: Due to insufficient documentation, the amount of questioned costs could not be determined. Recommendation: We recommend the Organization strengthen its compliance-related internal controls by: • Requiring standardized documentation to support compliance with each requirement. • Implementing periodic reviews of documentation completeness before charging costs to federal awards. • Providing training to staff responsible for grant management on compliance and record retention requirements. • Retain all documentation related to federal awards in a central location. Views of responsible officials: Management agrees with the finding and the recommendation. Corrective action plan: See Management’s Corrective Action Plan (Unaudited).
Finding 2020-006: Subrecipient Monitoring Federal Programs: Research and Development Cluster: 47.076 - STEM +C Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As stated in 2 CFR 200.331 part (b), all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring procedures to prescribe to each individual subrecipient. Condition: During our audit work over subrecipient monitoring, we were unable to verify that pre-award risk assessment procedures were performed. It is our understanding that AAPT has ongoing relationships with these subrecipients and evaluation of these subrecipients' risk is a continual process; however, these procedures were not documented. Cause: AAPT’s internal policies and procedures governing risk assessment on subrecipient was not performed. Effect or Potential Effect: AAPT could inadvertently engage in relationships with subrecipients of higher risk without the appropriate level of oversight to ensure subrecipients are expending funds in accordance with the provisions and terms of the subaward. Questioned Costs: None noted. Context: Our audit procedures consisted of examining documentation of the subrecipient monitoring process, and evaluating internal controls over the process. Identification as a Repeat Finding, if Applicable: 2019-005. Recommendation: We recommend AAPT follow their internal policies and procedures surrounding subrecipients and document the risk assessment criteria for the purpose of determining the expected level of oversight during the period of performance. This evaluation should include a scaling system, such as high, medium or low risk (for example), and the monitoring tools and procedures to be performed at each of these levels (additional training, on-site reviews, types of and frequency of reporting, etc.). Views of Responsible Officials and Planned Corrective Actions: Management will continue to perform risk assessment procedures and will thoroughly document the processes and evaluations. Anticipated Completion Date: 12/17/2021 Responsible Official: Michael Brosnan, CFO
Finding 2020-006: Subrecipient Monitoring Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1640791 (9/15/2016 – 8/31/2022) Significant Deficiency in Internal Controls Over Compliance, Other matters Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As stated in 2 CFR 200.331 part (b), all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring procedures to prescribe to each individual subrecipient. Condition: During our audit work over subrecipient monitoring, we were unable to verify that pre-award risk assessment procedures were performed. It is our understanding that AAPT has ongoing relationships with these subrecipients and evaluation of these subrecipients' risk is a continual process; however, these procedures were not documented. Cause: AAPT’s internal policies and procedures governing risk assessment on subrecipient was not performed. Effect or Potential Effect: AAPT could inadvertently engage in relationships with subrecipients of higher risk without the appropriate level of oversight to ensure subrecipients are expending funds in accordance with the provisions and terms of the subaward. Questioned Costs: None noted. Context: Our audit procedures consisted of examining documentation of the subrecipient monitoring process, and evaluating internal controls over the process. Identification as a Repeat Finding, if Applicable: 2019-005. Recommendation: We recommend AAPT follow their internal policies and procedures surrounding subrecipients and document the risk assessment criteria for the purpose of determining the expected level of oversight during the period of performance. This evaluation should include a scaling system, such as high, medium or low risk (for example), and the monitoring tools and procedures to be performed at each of these levels (additional training, on-site reviews, types of and frequency of reporting, etc.). Views of Responsible Officials and Planned Corrective Actions: Management will continue to perform risk assessment procedures and will thoroughly document the processes and evaluations. Anticipated Completion Date: 12/31/2022 Responsible Official: Michael Brosnan, CFO
Finding 2020-006: Subrecipient Monitoring Federal Programs: Research and Development Cluster: 47.076 - STEM +C Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As stated in 2 CFR 200.331 part (b), all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring procedures to prescribe to each individual subrecipient. Condition: During our audit work over subrecipient monitoring, we were unable to verify that pre-award risk assessment procedures were performed. It is our understanding that AAPT has ongoing relationships with these subrecipients and evaluation of these subrecipients' risk is a continual process; however, these procedures were not documented. Cause: AAPT’s internal policies and procedures governing risk assessment on subrecipient was not performed. Effect or Potential Effect: AAPT could inadvertently engage in relationships with subrecipients of higher risk without the appropriate level of oversight to ensure subrecipients are expending funds in accordance with the provisions and terms of the subaward. Questioned Costs: None noted. Context: Our audit procedures consisted of examining documentation of the subrecipient monitoring process, and evaluating internal controls over the process. Identification as a Repeat Finding, if Applicable: 2019-005. Recommendation: We recommend AAPT follow their internal policies and procedures surrounding subrecipients and document the risk assessment criteria for the purpose of determining the expected level of oversight during the period of performance. This evaluation should include a scaling system, such as high, medium or low risk (for example), and the monitoring tools and procedures to be performed at each of these levels (additional training, on-site reviews, types of and frequency of reporting, etc.). Views of Responsible Officials and Planned Corrective Actions: Management will continue to perform risk assessment procedures and will thoroughly document the processes and evaluations. Anticipated Completion Date: 12/17/2021 Responsible Official: Michael Brosnan, CFO
Finding 2020-006: Subrecipient Monitoring Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1640791 (9/15/2016 – 8/31/2022) Significant Deficiency in Internal Controls Over Compliance, Other matters Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As stated in 2 CFR 200.331 part (b), all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring procedures to prescribe to each individual subrecipient. Condition: During our audit work over subrecipient monitoring, we were unable to verify that pre-award risk assessment procedures were performed. It is our understanding that AAPT has ongoing relationships with these subrecipients and evaluation of these subrecipients' risk is a continual process; however, these procedures were not documented. Cause: AAPT’s internal policies and procedures governing risk assessment on subrecipient was not performed. Effect or Potential Effect: AAPT could inadvertently engage in relationships with subrecipients of higher risk without the appropriate level of oversight to ensure subrecipients are expending funds in accordance with the provisions and terms of the subaward. Questioned Costs: None noted. Context: Our audit procedures consisted of examining documentation of the subrecipient monitoring process, and evaluating internal controls over the process. Identification as a Repeat Finding, if Applicable: 2019-005. Recommendation: We recommend AAPT follow their internal policies and procedures surrounding subrecipients and document the risk assessment criteria for the purpose of determining the expected level of oversight during the period of performance. This evaluation should include a scaling system, such as high, medium or low risk (for example), and the monitoring tools and procedures to be performed at each of these levels (additional training, on-site reviews, types of and frequency of reporting, etc.). Views of Responsible Officials and Planned Corrective Actions: Management will continue to perform risk assessment procedures and will thoroughly document the processes and evaluations. Anticipated Completion Date: 12/31/2022 Responsible Official: Michael Brosnan, CFO
Federal Program Information Federal Agency: National Endowment for the Arts Award Name(s): Promotion of the Arts Partnership Agreements Assistance Listing Number(s): 45.025 Award Year: 2020 Compliance Requirement: Subrecipient Monitoring Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information as required in 2 CFR 200.331(a). Additionally, a pass-through entity must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward as required in 2 CFR 200.331(b). Condition and Context During our audit, we tested a sample of 16 of 105 subrecipients to determine if the subrecipient agreements contained all required elements per 2 CFR 200.331(a) and ensure sufficient evaluation of the subrecipient’s risk of noncompliance was performed. As a result of our testing, it was identified that the agreements tested did not contain the subrecipient’s unique entity identifier, federal award identification number, federal award date, and federal award project description. Additionally, the Organization did not perform an evaluation of the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring. Cause The Organization did not have adequate controls in place to ensure all required elements were included in subrecipient agreements or to evaluate risk of subrecipient’s noncompliance. Effect or Potential Effect Due to the weakness in internal controls and compliance finding noted above, the Organization did not comply with the requirements of the Uniform Guidance regarding communication to subrecipients all the specified elements in 2 CFR 200.331. This impacts the subrecipients’ ability to properly identify federal funding. No questioned costs are reported as this requirement is administrative in nature. Recommendation The Organization should update its subrecipient agreements, policies, and procedures to ensure inclusion of all required elements and implement risk assessment procedures to comply with the Uniform Guidance. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-thru entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a single audit and the extent to which the same or similar subaward has been audited as a major program; and (3) Whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the City would then have to consider the extent to which monitoring procedures are required. At a minimum, the City must, (1) Review financial and performance reports required by the City, (2) Follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the City detected through audits, on-site reviews, and other means, and (3) Issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the City as required by Section 200.521 of the Uniform Guidance. Additionally, the City must perform monitoring visits as stipulated in the contracts between the City and the subrecipients. Condition: The City does not have policies and procedures in place to perform the required risk assessment of subrecipients to determine the extent of monitoring procedures, and then perform and document the monitoring procedures performed. Cause: There is no documentation of any subrecipient risk assessment being performed for grants provided to subrecipients for 2019, and only partial documentation of any subrecipient monitoring procedures being performed. Effect: Subrecipient monitoring procedures were not properly performed and documented by the City. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to perform risk assessment of subrecipients, in order to determine the extent of monitoring procedures and performance of the monitoring procedures themselves. Recommendation: We recommend the City implement procedures to ensure risk assessment of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-thru entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a single audit and the extent to which the same or similar subaward has been audited as a major program; and (3) Whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the City would then have to consider the extent to which monitoring procedures are required. At a minimum, the City must, (1) Review financial and performance reports required by the City, (2) Follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the City detected through audits, on-site reviews, and other means, and (3) Issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the City as required by Section 200.521 of the Uniform Guidance. Additionally, the City must perform monitoring visits as stipulated in the contracts between the City and the subrecipients. Condition: The City does not have policies and procedures in place to perform the required risk assessment of subrecipients to determine the extent of monitoring procedures, and then perform and document the monitoring procedures performed. Cause: There is no documentation of any subrecipient risk assessment being performed for grants provided to subrecipients for 2019, and only partial documentation of any subrecipient monitoring procedures being performed. Effect: Subrecipient monitoring procedures were not properly performed and documented by the City. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to perform risk assessment of subrecipients, in order to determine the extent of monitoring procedures and performance of the monitoring procedures themselves. Recommendation: We recommend the City implement procedures to ensure risk assessment of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-thru entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a single audit and the extent to which the same or similar subaward has been audited as a major program; and (3) Whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the City would then have to consider the extent to which monitoring procedures are required. At a minimum, the City must, (1) Review financial and performance reports required by the City, (2) Follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the City detected through audits, on-site reviews, and other means, and (3) Issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the City as required by Section 200.521 of the Uniform Guidance. Additionally, the City must perform monitoring visits as stipulated in the contracts between the City and the subrecipients. Condition: The City does not have policies and procedures in place to perform the required risk assessment of subrecipients to determine the extent of monitoring procedures, and then perform and document the monitoring procedures performed. Cause: There is no documentation of any subrecipient risk assessment being performed for grants provided to subrecipients for 2019, and only partial documentation of any subrecipient monitoring procedures being performed. Effect: Subrecipient monitoring procedures were not properly performed and documented by the City. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to perform risk assessment of subrecipients, in order to determine the extent of monitoring procedures and performance of the monitoring procedures themselves. Recommendation: We recommend the City implement procedures to ensure risk assessment of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-thru entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a single audit and the extent to which the same or similar subaward has been audited as a major program; and (3) Whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the City would then have to consider the extent to which monitoring procedures are required. At a minimum, the City must, (1) Review financial and performance reports required by the City, (2) Follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the City detected through audits, on-site reviews, and other means, and (3) Issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the City as required by Section 200.521 of the Uniform Guidance. Additionally, the City must perform monitoring visits as stipulated in the contracts between the City and the subrecipients. Condition: The City does not have policies and procedures in place to perform the required risk assessment of subrecipients to determine the extent of monitoring procedures, and then perform and document the monitoring procedures performed. Cause: There is no documentation of any subrecipient risk assessment being performed for grants provided to subrecipients for 2019, and only partial documentation of any subrecipient monitoring procedures being performed. Effect: Subrecipient monitoring procedures were not properly performed and documented by the City. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to perform risk assessment of subrecipients, in order to determine the extent of monitoring procedures and performance of the monitoring procedures themselves. Recommendation: We recommend the City implement procedures to ensure risk assessment of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-thru entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a single audit and the extent to which the same or similar subaward has been audited as a major program; and (3) Whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the City would then have to consider the extent to which monitoring procedures are required. At a minimum, the City must, (1) Review financial and performance reports required by the City, (2) Follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the City detected through audits, on-site reviews, and other means, and (3) Issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the City as required by Section 200.521 of the Uniform Guidance. Additionally, the City must perform monitoring visits as stipulated in the contracts between the City and the subrecipients. Condition: The City does not have policies and procedures in place to perform the required risk assessment of subrecipients to determine the extent of monitoring procedures, and then perform and document the monitoring procedures performed. Cause: There is no documentation of any subrecipient risk assessment being performed for grants provided to subrecipients for 2019, and only partial documentation of any subrecipient monitoring procedures being performed. Effect: Subrecipient monitoring procedures were not properly performed and documented by the City. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to perform risk assessment of subrecipients, in order to determine the extent of monitoring procedures and performance of the monitoring procedures themselves. Recommendation: We recommend the City implement procedures to ensure risk assessment of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-thru entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a single audit and the extent to which the same or similar subaward has been audited as a major program; and (3) Whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the City would then have to consider the extent to which monitoring procedures are required. At a minimum, the City must, (1) Review financial and performance reports required by the City, (2) Follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the City detected through audits, on-site reviews, and other means, and (3) Issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the City as required by Section 200.521 of the Uniform Guidance. Additionally, the City must perform monitoring visits as stipulated in the contracts between the City and the subrecipients. Condition: The City does not have policies and procedures in place to perform the required risk assessment of subrecipients to determine the extent of monitoring procedures, and then perform and document the monitoring procedures performed. Cause: There is no documentation of any subrecipient risk assessment being performed for grants provided to subrecipients for 2019, and only partial documentation of any subrecipient monitoring procedures being performed. Effect: Subrecipient monitoring procedures were not properly performed and documented by the City. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to perform risk assessment of subrecipients, in order to determine the extent of monitoring procedures and performance of the monitoring procedures themselves. Recommendation: We recommend the City implement procedures to ensure risk assessment of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-thru entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a single audit and the extent to which the same or similar subaward has been audited as a major program; and (3) Whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the City would then have to consider the extent to which monitoring procedures are required. At a minimum, the City must, (1) Review financial and performance reports required by the City, (2) Follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the City detected through audits, on-site reviews, and other means, and (3) Issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the City as required by Section 200.521 of the Uniform Guidance. Additionally, the City must perform monitoring visits as stipulated in the contracts between the City and the subrecipients. Condition: The City does not have policies and procedures in place to perform the required risk assessment of subrecipients to determine the extent of monitoring procedures, and then perform and document the monitoring procedures performed. Cause: There is no documentation of any subrecipient risk assessment being performed for grants provided to subrecipients for 2019, and only partial documentation of any subrecipient monitoring procedures being performed. Effect: Subrecipient monitoring procedures were not properly performed and documented by the City. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to perform risk assessment of subrecipients, in order to determine the extent of monitoring procedures and performance of the monitoring procedures themselves. Recommendation: We recommend the City implement procedures to ensure risk assessment of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-thru entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a single audit and the extent to which the same or similar subaward has been audited as a major program; and (3) Whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the City would then have to consider the extent to which monitoring procedures are required. At a minimum, the City must, (1) Review financial and performance reports required by the City, (2) Follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the City detected through audits, on-site reviews, and other means, and (3) Issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the City as required by Section 200.521 of the Uniform Guidance. Additionally, the City must perform monitoring visits as stipulated in the contracts between the City and the subrecipients. Condition: The City does not have policies and procedures in place to perform the required risk assessment of subrecipients to determine the extent of monitoring procedures, and then perform and document the monitoring procedures performed. Cause: There is no documentation of any subrecipient risk assessment being performed for grants provided to subrecipients for 2019, and only partial documentation of any subrecipient monitoring procedures being performed. Effect: Subrecipient monitoring procedures were not properly performed and documented by the City. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to perform risk assessment of subrecipients, in order to determine the extent of monitoring procedures and performance of the monitoring procedures themselves. Recommendation: We recommend the City implement procedures to ensure risk assessment of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-thru entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a single audit and the extent to which the same or similar subaward has been audited as a major program; and (3) Whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the City would then have to consider the extent to which monitoring procedures are required. At a minimum, the City must, (1) Review financial and performance reports required by the City, (2) Follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the City detected through audits, on-site reviews, and other means, and (3) Issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the City as required by Section 200.521 of the Uniform Guidance. Additionally, the City must perform monitoring visits as stipulated in the contracts between the City and the subrecipients. Condition: The City does not have policies and procedures in place to perform the required risk assessment of subrecipients to determine the extent of monitoring procedures, and then perform and document the monitoring procedures performed. Cause: There is no documentation of any subrecipient risk assessment being performed for grants provided to subrecipients for 2019, and only partial documentation of any subrecipient monitoring procedures being performed. Effect: Subrecipient monitoring procedures were not properly performed and documented by the City. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to perform risk assessment of subrecipients, in order to determine the extent of monitoring procedures and performance of the monitoring procedures themselves. Recommendation: We recommend the City implement procedures to ensure risk assessment of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-thru entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a single audit and the extent to which the same or similar subaward has been audited as a major program; and (3) Whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the City would then have to consider the extent to which monitoring procedures are required. At a minimum, the City must, (1) Review financial and performance reports required by the City, (2) Follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the City detected through audits, on-site reviews, and other means, and (3) Issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the City as required by Section 200.521 of the Uniform Guidance. Additionally, the City must perform monitoring visits as stipulated in the contracts between the City and the subrecipients. Condition: The City does not have policies and procedures in place to perform the required risk assessment of subrecipients to determine the extent of monitoring procedures, and then perform and document the monitoring procedures performed. Cause: There is no documentation of any subrecipient risk assessment being performed for grants provided to subrecipients for 2019, and only partial documentation of any subrecipient monitoring procedures being performed. Effect: Subrecipient monitoring procedures were not properly performed and documented by the City. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to perform risk assessment of subrecipients, in order to determine the extent of monitoring procedures and performance of the monitoring procedures themselves. Recommendation: We recommend the City implement procedures to ensure risk assessment of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward.