(2022-035) Title: Internal control over CNC subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child Nutrition Cluster (COVID-19) Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Federal Award Identification Number: 214ME300L1603, 214ME301N1099, 214ME301N1199, 224ME301N1199, 224ME300L1603, 214ME102H1703, 224ME902N8903 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited as required. Condition: The Department of Education (DOE) School Finance and Operations is responsible for tracking and reviewing subrecipient audits on behalf of the Child Nutrition Cluster (CNC). CNC program subrecipients include schools that are provided Federal funds to support food service programs. The Office of the State Auditor (OSA) requested a list of subrecipients that required audits in fiscal year 2022 from DOE to test compliance with Federal regulations. OSA independently queried the State?s accounting system to develop a separate list for comparison and to ensure completeness. OSA compared DOE?s tracking to OSA?s generated list and found two subrecipients that were excluded from DOE?s tracking. DOE?s tracking excluded two private schools that received Federal funds in excess of the $750,000 Single Audit requirement; therefore, the audits for the two schools were not received or reviewed. Context: In fiscal year 2022, $113 million was provided to 254 subrecipients. Approximately 120 subrecipients were required to have an audit in accordance with Federal regulations. Cause: ? Lack of adequate policies and procedures. DOE policies do not provide guidance over tracking audits of private schools. ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be complying with Federal statutes, regulations, or the terms and conditions of the subaward. Recommendation: We recommend that the Department implement policies and procedures to ensure that audit reports for all subrecipients, including private schools, receiving over $750,000 in Federal awards are tracked, received, and reviewed. Corrective Action Plan: See F-15 Management?s Response: The Department agrees with this finding. Child Nutrition will create policies and procedures to collect, track, and review single audits for private schools receiving over $750,000 in Federal awards. Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880 (State Number: 22-1203-04)
(2022-035) Title: Internal control over CNC subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child Nutrition Cluster (COVID-19) Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Federal Award Identification Number: 214ME300L1603, 214ME301N1099, 214ME301N1199, 224ME301N1199, 224ME300L1603, 214ME102H1703, 224ME902N8903 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited as required. Condition: The Department of Education (DOE) School Finance and Operations is responsible for tracking and reviewing subrecipient audits on behalf of the Child Nutrition Cluster (CNC). CNC program subrecipients include schools that are provided Federal funds to support food service programs. The Office of the State Auditor (OSA) requested a list of subrecipients that required audits in fiscal year 2022 from DOE to test compliance with Federal regulations. OSA independently queried the State?s accounting system to develop a separate list for comparison and to ensure completeness. OSA compared DOE?s tracking to OSA?s generated list and found two subrecipients that were excluded from DOE?s tracking. DOE?s tracking excluded two private schools that received Federal funds in excess of the $750,000 Single Audit requirement; therefore, the audits for the two schools were not received or reviewed. Context: In fiscal year 2022, $113 million was provided to 254 subrecipients. Approximately 120 subrecipients were required to have an audit in accordance with Federal regulations. Cause: ? Lack of adequate policies and procedures. DOE policies do not provide guidance over tracking audits of private schools. ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be complying with Federal statutes, regulations, or the terms and conditions of the subaward. Recommendation: We recommend that the Department implement policies and procedures to ensure that audit reports for all subrecipients, including private schools, receiving over $750,000 in Federal awards are tracked, received, and reviewed. Corrective Action Plan: See F-15 Management?s Response: The Department agrees with this finding. Child Nutrition will create policies and procedures to collect, track, and review single audits for private schools receiving over $750,000 in Federal awards. Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880 (State Number: 22-1203-04)
(2022-035) Title: Internal control over CNC subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child Nutrition Cluster (COVID-19) Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Federal Award Identification Number: 214ME300L1603, 214ME301N1099, 214ME301N1199, 224ME301N1199, 224ME300L1603, 214ME102H1703, 224ME902N8903 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited as required. Condition: The Department of Education (DOE) School Finance and Operations is responsible for tracking and reviewing subrecipient audits on behalf of the Child Nutrition Cluster (CNC). CNC program subrecipients include schools that are provided Federal funds to support food service programs. The Office of the State Auditor (OSA) requested a list of subrecipients that required audits in fiscal year 2022 from DOE to test compliance with Federal regulations. OSA independently queried the State?s accounting system to develop a separate list for comparison and to ensure completeness. OSA compared DOE?s tracking to OSA?s generated list and found two subrecipients that were excluded from DOE?s tracking. DOE?s tracking excluded two private schools that received Federal funds in excess of the $750,000 Single Audit requirement; therefore, the audits for the two schools were not received or reviewed. Context: In fiscal year 2022, $113 million was provided to 254 subrecipients. Approximately 120 subrecipients were required to have an audit in accordance with Federal regulations. Cause: ? Lack of adequate policies and procedures. DOE policies do not provide guidance over tracking audits of private schools. ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be complying with Federal statutes, regulations, or the terms and conditions of the subaward. Recommendation: We recommend that the Department implement policies and procedures to ensure that audit reports for all subrecipients, including private schools, receiving over $750,000 in Federal awards are tracked, received, and reviewed. Corrective Action Plan: See F-15 Management?s Response: The Department agrees with this finding. Child Nutrition will create policies and procedures to collect, track, and review single audits for private schools receiving over $750,000 in Federal awards. Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880 (State Number: 22-1203-04)
(2022-042) Title: Internal control over CACFP subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child and Adult Care Food Program (CACFP) Assistance Listing Number: 10.558 Federal Award Identification Number: 214ME301N1099, 214ME301N1199, 224ME301N1199, 214ME320N1150, 214ME325N2020, 224ME320N1150, 224ME325N2020, 214ME202H1706, 204ME320N1050 Compliance Area: Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited as required. Condition: The Child and Adult Care Food Program (CACFP) provides nutritious foods that contribute to wellness, healthy growth, and development of eligible children and adults receiving care in day-care centers, day-care homes, and at-risk after school snack programs. Child Nutrition Services (CNS) is responsible for monitoring 104 subrecipients that administer these services. Those monitoring procedures include verifying that subrecipients that expend over $750,000 obtain a Single Audit in accordance with Federal regulations. CACFP was previously administered by the State Department of Health and Human Services (DHHS) and subrecipient audits were tracked, received, and reviewed by DHHS? Division of Audit. Prior to fiscal year 2022, the administration of CACFP was moved to the Department of Education (DOE). DOE School Finance and Operations is responsible for the tracking, receipt, and review of subrecipient audits for most programs administered by DOE. CNS asserted that subrecipient audits for private non-profit institutions were received and forwarded to DOE School Finance and Operations for review; however, DOE only stored the audits. Neither CNS nor DOE could provide documentation to support that tracking of subrecipient audit reports was maintained or that reports were received and reviewed. As a result, 19 private non-profit subrecipients that reported receiving over $750,000 in Federal funds and required audits were not reviewed. Context: In fiscal year 2022, $9.3 million in CACFP funds was provided to 104 subrecipients, 51 of which are private non-profit subrecipients and 19 were required to have an audit. Cause: ? Lack of policies and procedures. CNS and DOE School Finance and Operations have not defined roles and responsibilities for tracking, receiving, and reviewing subrecipient audit reports. ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be complying with Federal statutes, regulations, or the terms and conditions of the subaward. Recommendation: We recommend that CNS and DOE School Finance and Operations collaborate on implementing policies and procedures that define the roles and responsibilities for tracking, receipt, and review of subrecipient audits. Corrective Action Plan: See F-17 Management?s Response: The Department agrees with this finding. Child Nutrition will implement policies and procedures for the tracking, receipt, and review of audits for subrecipients that expend over $750,000, in accordance with Federal regulations. Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880 (State Number: 22-1115-04)
(2022-044) Title: Internal control over CACFP subrecipient risk evaluation procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child and Adult Care Food Program (CACFP) Assistance Listing Number: 10.558 Federal Award Identification Number: 214ME301N1099, 214ME301N1199, 224ME301N1199, 214ME320N1150, 214ME325N2020, 224ME320N1150, 224ME325N2020, 214ME202H1706, 204ME320N1050 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department is required to 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. Condition: The Child and Adult Care Food Program (CACFP) provides nutritious foods that contribute to wellness, healthy growth, and development of eligible children and adults receiving care in day-care centers, day-care homes, and at-risk after school snack programs. The Department is responsible for monitoring 104 subrecipients that administer these services. The level of monitoring required by Federal regulations must be determined using a risk-based approach. Subrecipient risk evaluation should include considerations of: ? the subrecipient?s experience with the program, ? the results of subrecipient audits, ? changes in personnel or systems, and ? the extent of Federal awarding agency monitoring procedures. CACFP regulations require the Department to monitor 33.3 percent of total active facilities in each review cycle (annually). In addition, all facilities must be monitored at least once every three years and Sponsoring Organizations (SOs) with 100 or more facilities must be monitored once every two years. SOs provide administration and support for smaller facilities. Department subrecipient monitoring procedures are based on CACFP regulations and do not use the risk-based approach as required by Federal regulations. Context: In fiscal year 2022, CACFP expenditures totaled $9.4 million, of which $9.3 million was provided to 104 subrecipients. Cause: Lack of adequate policies and procedures Effect: ? Noncompliance with Federal regulations ? Subrecipients that are deemed higher risk may not be monitored on a more frequent basis. Conversely, subrecipients that are deemed lower risk may not be monitored on a less frequent basis, which would free resources and time to dedicate towards other higher risk subrecipients. Recommendation: We recommend that the Department review and update policies and procedures to incorporate Federal regulations along with program regulations. The risk evaluation process should be documented and retained. Corrective Action Plan: See F-17 Management?s Response: The Department agrees with this finding. The CACFP team will create a risk assessment tool to use in scheduling subrecipient reviews. Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880 (State Number: 22-1115-03)
(2022-035) Title: Internal control over CNC subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child Nutrition Cluster (COVID-19) Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Federal Award Identification Number: 214ME300L1603, 214ME301N1099, 214ME301N1199, 224ME301N1199, 224ME300L1603, 214ME102H1703, 224ME902N8903 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited as required. Condition: The Department of Education (DOE) School Finance and Operations is responsible for tracking and reviewing subrecipient audits on behalf of the Child Nutrition Cluster (CNC). CNC program subrecipients include schools that are provided Federal funds to support food service programs. The Office of the State Auditor (OSA) requested a list of subrecipients that required audits in fiscal year 2022 from DOE to test compliance with Federal regulations. OSA independently queried the State?s accounting system to develop a separate list for comparison and to ensure completeness. OSA compared DOE?s tracking to OSA?s generated list and found two subrecipients that were excluded from DOE?s tracking. DOE?s tracking excluded two private schools that received Federal funds in excess of the $750,000 Single Audit requirement; therefore, the audits for the two schools were not received or reviewed. Context: In fiscal year 2022, $113 million was provided to 254 subrecipients. Approximately 120 subrecipients were required to have an audit in accordance with Federal regulations. Cause: ? Lack of adequate policies and procedures. DOE policies do not provide guidance over tracking audits of private schools. ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be complying with Federal statutes, regulations, or the terms and conditions of the subaward. Recommendation: We recommend that the Department implement policies and procedures to ensure that audit reports for all subrecipients, including private schools, receiving over $750,000 in Federal awards are tracked, received, and reviewed. Corrective Action Plan: See F-15 Management?s Response: The Department agrees with this finding. Child Nutrition will create policies and procedures to collect, track, and review single audits for private schools receiving over $750,000 in Federal awards. Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880 (State Number: 22-1203-04)
(2022-035) Title: Internal control over CNC subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child Nutrition Cluster (COVID-19) Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Federal Award Identification Number: 214ME300L1603, 214ME301N1099, 214ME301N1199, 224ME301N1199, 224ME300L1603, 214ME102H1703, 224ME902N8903 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited as required. Condition: The Department of Education (DOE) School Finance and Operations is responsible for tracking and reviewing subrecipient audits on behalf of the Child Nutrition Cluster (CNC). CNC program subrecipients include schools that are provided Federal funds to support food service programs. The Office of the State Auditor (OSA) requested a list of subrecipients that required audits in fiscal year 2022 from DOE to test compliance with Federal regulations. OSA independently queried the State?s accounting system to develop a separate list for comparison and to ensure completeness. OSA compared DOE?s tracking to OSA?s generated list and found two subrecipients that were excluded from DOE?s tracking. DOE?s tracking excluded two private schools that received Federal funds in excess of the $750,000 Single Audit requirement; therefore, the audits for the two schools were not received or reviewed. Context: In fiscal year 2022, $113 million was provided to 254 subrecipients. Approximately 120 subrecipients were required to have an audit in accordance with Federal regulations. Cause: ? Lack of adequate policies and procedures. DOE policies do not provide guidance over tracking audits of private schools. ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be complying with Federal statutes, regulations, or the terms and conditions of the subaward. Recommendation: We recommend that the Department implement policies and procedures to ensure that audit reports for all subrecipients, including private schools, receiving over $750,000 in Federal awards are tracked, received, and reviewed. Corrective Action Plan: See F-15 Management?s Response: The Department agrees with this finding. Child Nutrition will create policies and procedures to collect, track, and review single audits for private schools receiving over $750,000 in Federal awards. Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880 (State Number: 22-1203-04)
(2022-049) Title: Internal control over ERA Program subrecipient monitoring needs improvement Prior Year Findings: None State Department: Economic and Community Development State Bureau: Commissioner?s Office Federal Agency: U.S. Department of the Treasury Assistance Listing Title: Emergency Rental Assistance Program (COVID-19) Assistance Listing Number: 21.023 Federal Award Identification Number: ERA0299, ERA0434, ERAE0515, ERAE0563 Compliance Area: Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must monitor the activities of the subrecipient as necessary to ensure that subawards are used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward, and that subaward performance goals are achieved. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited as required. Condition: In fiscal year 2022, the Department passed through Emergency Rental Assistance (ERA) Program funds to one subrecipient. Subrecipient monitoring procedures included providing Federal award information in grant award agreements and frequent communication with the subrecipient; however, the Department: ? did not adequately design and document ongoing monitoring activities to ensure that the subaward was used for authorized purposes and in compliance with Federal regulations. ? could not provide a documented review of the subrecipient?s audit report to verify compliance with Subpart F of 2 CFR 200 and to ensure that the subrecipient took timely and appropriate action on all deficiencies pertaining to the Department?s subaward. The Office of the State Auditor reviewed the subrecipient?s audit report covering a portion of fiscal year 2022 and noted findings related to the subaward that should have been considered in relation to the risk of subrecipient noncompliance and planned monitoring procedures. ? did not require submission of detailed expenditure information with the subrecipient?s requests for reimbursement of ERA Program funds. A summary spreadsheet outlining actual and projected expenditures for second-tier subrecipients was the only support provided to the Department with each reimbursement request. Context: The Department provided $245.8 million to the ERA subrecipient during fiscal year 2022. Cause: ? Lack of supervisory oversight ? Lack of adequate policies and procedures Effect: ? Noncompliance with Federal regulations ? Lack of ongoing subrecipient monitoring procedures could result in subrecipient noncompliance. Recommendation: We recommend that the Department develop and implement additional policies and procedures to require: ? ongoing subrecipient monitoring during the use of the subaward; ? receipt and documented review of subrecipient audits in order to consider the effects of audit results on subrecipient risk assessment and planned monitoring procedures; and ? receipt of detailed documentation in support of subrecipient reimbursement requests prior to payment approval. Corrective Action Plan: See F-19 Management?s Response: The Department agrees with this finding. Due to the Emergency Rental Assistance Program coming to a close, the Department plans on utilizing a consultant to assist with close out procedures that will ensure these subrecipient funds were used for authorized purposes and in compliance with Federal regulations. Additionally, the Department will ensure that the review of subrecipient audit reports are sufficiently documented. Contact: Deborah Johnson, Director, Office of Community Development, DECD, 207-624-9817 (State Number: 22-1695-02)
(2022-057) Title: Internal control over ESF subrecipient monitoring procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Federal Agency: U.S. Department of Education Assistance Listing Title: Education Stabilization Fund (ESF) (COVID-19) Assistance Listing Number: 84.425D, 84.425R, 84.425U Federal Award Identification Number: S425C200004, S425C210004, S425D200004, S425D210004, S425U210004, S425W210020, S425R210044, S425B200039 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.313; 2 CFR 200.332 The Department must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Department is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. For equipment acquired with Federal funding, records must be maintained that include: ? a description and identification number; ? the source of funding, including the Federal Award Identification Number; ? who holds title and the acquisition date; ? the cost of the property, including the percentage of Federal participation in the project costs for the Federal award under which the property was acquired; ? the location, use and condition; and ? any ultimate disposition data including the date of disposal and sale price of the property. A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. The Department must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: The Education Stabilization Fund (ESF) provides funding to school administrative units (SAUs) to purchase equipment for use in preventing, preparing for, or responding to the COVID-19 pandemic. SAUs were required to submit applications to the Office of Federal Emergency Relief Programs (OFERP) under the Department of Education outlining identified uses for ESF including planned equipment purchases. Program coordinators within OFERP were responsible for reviewing and approving applications submitted by SAUs. Once there was an approved application on file, SAUs could submit reimbursement requests to the Department for equipment purchases identified and approved in the application. All SAU equipment purchases reimbursed with ESF are subject to applicable inventory control, log maintenance, and disposition requirements consistent with Federal regulations for equipment and real property management. During fiscal year 2022, the Department did not have policies and procedures in place to track SAU equipment purchases reimbursed with ESF; therefore, the Department does not have assurance that: ? a complete and accurate record of all equipment purchased with ESF funds was maintained by each SAU. ? proper monitoring activities surrounding subrecipient compliance with Federal regulations for equipment and real property management were conducted. Context: In fiscal year 2022, ESF expenditures totaled $126.4 million, of which $120.6 million was paid to subrecipient SAUs. Cause: ? Lack of policies and procedures ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be in compliance with equipment and real property management requirements. ? Assets purchased with ESF funds may not be properly safeguarded or maintained. Recommendation: We recommend that the Department implement policies and procedures to ensure that a complete and accurate record of all equipment purchased under ESF is maintained by the Department and by each SAU. This record should be utilized during subrecipient monitoring activities to verify subrecipient compliance with Federal regulations. Corrective Action Plan: See F-21 Management?s Response: The Department agrees with this finding. The Office of Federal Emergency Relief Programs will develop and implement policies and procedures so that complete and accurate records of all equipment purchased under ESF will be maintained by each SAU and the Department when collected during subrecipient monitoring. Contact: Shelly Chasse-Johndro, Director of OFERP, DOE, 207-458-3180 (State Number: 22-1235-06)
(2022-057) Title: Internal control over ESF subrecipient monitoring procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Federal Agency: U.S. Department of Education Assistance Listing Title: Education Stabilization Fund (ESF) (COVID-19) Assistance Listing Number: 84.425D, 84.425R, 84.425U Federal Award Identification Number: S425C200004, S425C210004, S425D200004, S425D210004, S425U210004, S425W210020, S425R210044, S425B200039 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.313; 2 CFR 200.332 The Department must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Department is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. For equipment acquired with Federal funding, records must be maintained that include: ? a description and identification number; ? the source of funding, including the Federal Award Identification Number; ? who holds title and the acquisition date; ? the cost of the property, including the percentage of Federal participation in the project costs for the Federal award under which the property was acquired; ? the location, use and condition; and ? any ultimate disposition data including the date of disposal and sale price of the property. A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. The Department must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: The Education Stabilization Fund (ESF) provides funding to school administrative units (SAUs) to purchase equipment for use in preventing, preparing for, or responding to the COVID-19 pandemic. SAUs were required to submit applications to the Office of Federal Emergency Relief Programs (OFERP) under the Department of Education outlining identified uses for ESF including planned equipment purchases. Program coordinators within OFERP were responsible for reviewing and approving applications submitted by SAUs. Once there was an approved application on file, SAUs could submit reimbursement requests to the Department for equipment purchases identified and approved in the application. All SAU equipment purchases reimbursed with ESF are subject to applicable inventory control, log maintenance, and disposition requirements consistent with Federal regulations for equipment and real property management. During fiscal year 2022, the Department did not have policies and procedures in place to track SAU equipment purchases reimbursed with ESF; therefore, the Department does not have assurance that: ? a complete and accurate record of all equipment purchased with ESF funds was maintained by each SAU. ? proper monitoring activities surrounding subrecipient compliance with Federal regulations for equipment and real property management were conducted. Context: In fiscal year 2022, ESF expenditures totaled $126.4 million, of which $120.6 million was paid to subrecipient SAUs. Cause: ? Lack of policies and procedures ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be in compliance with equipment and real property management requirements. ? Assets purchased with ESF funds may not be properly safeguarded or maintained. Recommendation: We recommend that the Department implement policies and procedures to ensure that a complete and accurate record of all equipment purchased under ESF is maintained by the Department and by each SAU. This record should be utilized during subrecipient monitoring activities to verify subrecipient compliance with Federal regulations. Corrective Action Plan: See F-21 Management?s Response: The Department agrees with this finding. The Office of Federal Emergency Relief Programs will develop and implement policies and procedures so that complete and accurate records of all equipment purchased under ESF will be maintained by each SAU and the Department when collected during subrecipient monitoring. Contact: Shelly Chasse-Johndro, Director of OFERP, DOE, 207-458-3180 (State Number: 22-1235-06)
(2022-057) Title: Internal control over ESF subrecipient monitoring procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Federal Agency: U.S. Department of Education Assistance Listing Title: Education Stabilization Fund (ESF) (COVID-19) Assistance Listing Number: 84.425D, 84.425R, 84.425U Federal Award Identification Number: S425C200004, S425C210004, S425D200004, S425D210004, S425U210004, S425W210020, S425R210044, S425B200039 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.313; 2 CFR 200.332 The Department must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Department is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. For equipment acquired with Federal funding, records must be maintained that include: ? a description and identification number; ? the source of funding, including the Federal Award Identification Number; ? who holds title and the acquisition date; ? the cost of the property, including the percentage of Federal participation in the project costs for the Federal award under which the property was acquired; ? the location, use and condition; and ? any ultimate disposition data including the date of disposal and sale price of the property. A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. The Department must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: The Education Stabilization Fund (ESF) provides funding to school administrative units (SAUs) to purchase equipment for use in preventing, preparing for, or responding to the COVID-19 pandemic. SAUs were required to submit applications to the Office of Federal Emergency Relief Programs (OFERP) under the Department of Education outlining identified uses for ESF including planned equipment purchases. Program coordinators within OFERP were responsible for reviewing and approving applications submitted by SAUs. Once there was an approved application on file, SAUs could submit reimbursement requests to the Department for equipment purchases identified and approved in the application. All SAU equipment purchases reimbursed with ESF are subject to applicable inventory control, log maintenance, and disposition requirements consistent with Federal regulations for equipment and real property management. During fiscal year 2022, the Department did not have policies and procedures in place to track SAU equipment purchases reimbursed with ESF; therefore, the Department does not have assurance that: ? a complete and accurate record of all equipment purchased with ESF funds was maintained by each SAU. ? proper monitoring activities surrounding subrecipient compliance with Federal regulations for equipment and real property management were conducted. Context: In fiscal year 2022, ESF expenditures totaled $126.4 million, of which $120.6 million was paid to subrecipient SAUs. Cause: ? Lack of policies and procedures ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be in compliance with equipment and real property management requirements. ? Assets purchased with ESF funds may not be properly safeguarded or maintained. Recommendation: We recommend that the Department implement policies and procedures to ensure that a complete and accurate record of all equipment purchased under ESF is maintained by the Department and by each SAU. This record should be utilized during subrecipient monitoring activities to verify subrecipient compliance with Federal regulations. Corrective Action Plan: See F-21 Management?s Response: The Department agrees with this finding. The Office of Federal Emergency Relief Programs will develop and implement policies and procedures so that complete and accurate records of all equipment purchased under ESF will be maintained by each SAU and the Department when collected during subrecipient monitoring. Contact: Shelly Chasse-Johndro, Director of OFERP, DOE, 207-458-3180 (State Number: 22-1235-06)
(2022-058) Title: Internal control over ICA program subrecipient monitoring procedures needs improvement Prior Year Findings: None State Department: Health and Human Services State Bureau: Maine Center for Disease Control & Prevention Federal Agency: U.S. Department of Health and Human Services Assistance Listing Title: Immunization Cooperative Agreements (COVID-19) Assistance Listing Number: 93.268 Federal Award Identification Number: NH23IP922604 Compliance Area: Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must: ? include Federal award information in the subaward that enables subrecipients to identify the source of the Federal award, as well as certain subrecipient information. ? evaluate each subrecipient?s risk of noncompliance with Federal regulations for the purposes of determining the appropriate level of subrecipient monitoring to be performed. ? monitor the activities of the subrecipient as necessary to ensure that subawards are used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward, and that subaward performance goals are achieved. Condition: The Department is responsible for ensuring subrecipients comply with Federal requirements by: ? reviewing subrecipient grant awards to ensure accurate Federal award identification information is included to allow subrecipients to accurately identify the source of the subawards; ? utilizing risk evaluations to determine the appropriate level of monitoring activities to be performed that correspond to the results of those risk evaluations; and ? performing ongoing monitoring activities to ensure that the subaward was used for authorized purposes and in compliance with Federal regulations. The Office of the State Auditor (OSA) tested compliance with subrecipient monitoring requirements for 7 subrecipients and found that: ? 3 subawards did not properly identify required Federal award information: o 2 subawards were missing the subrecipient?s Data Universal Numbering System (DUNS) number. o 2 subawards reported the wrong Assistance Listing Number. ? 2 subrecipients were deemed ?higher risk? after the Department performed a risk evaluation; however, the Department could not provide documentation to support that additional monitoring activities were performed in response to the ?higher risk? designation. ? 80 performance reports were required to be completed and submitted for fiscal year 2022 to ensure subaward performance goals are achieved. o 47 reports were provided to the auditor but lacked evidence of supervisory review. o 33 reports could not be provided. ? 52 financial reports were required to be completed and submitted for fiscal year 2022 to ensure subawards are used for approved budgeted expenditures. o 32 reports were provided to the auditor but lacked evidence of supervisory review. o 20 reports could not be provided. The Department could not provide any further documentation to support subrecipient monitoring procedures occurred during fiscal year 2022 to ensure that the subaward was used for authorized purposes. OSA selected a non-statistical random sample. Context: The Department provided $2.5 million to 35 Immunization Cooperative Agreements (ICA) program subrecipients in fiscal year 2022. Cause: ? Lack of adequate policies and procedures ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Lack of ongoing subrecipient monitoring procedures could result in undetected subrecipient noncompliance. Recommendation: We recommend that the Department implement policies and procedures to ensure that: ? subaward agreements include all required information and are accurate; ? risk evaluations are utilized to determine the appropriate level of monitoring activities to be performed; and ? ongoing subrecipient monitoring is completed during the subaward and documented. This will ensure that the Department is in compliance with subrecipient monitoring requirements. Corrective Action Plan: See F-22 Management?s Response: The Department agrees with this finding. The Department initiated these subrecipient agreements to ensure equitable access to COVID-19 vaccines. As a result of these agreements, Maine had one of the best vaccine roll-outs in the country, including among Black, Indigenous, and People of Color. Some of the information requested by OSA was unable to be accessed because it was saved in individual staff files which were moved when an employee was transferred or left employment with the Department. The Department will implement processes in SFY23 to improve record keeping for these subawards including: 1) reviewing subaward agreements using a checklist to ensure they include all the required information and are accurate; 2) ensuring that risk evaluations are utilized to determine the appropriate level of monitoring; and 3) improving and centralizing subrecipient monitoring documentation within the Office of Population Health Equity (OPHE) at Maine CDC. Contact: Ian Yaffe, Director, Office of Population Health Equity, DHHS, 207- 592-1481 (State Number: 22-1118-03)
(2022-058) Title: Internal control over ICA program subrecipient monitoring procedures needs improvement Prior Year Findings: None State Department: Health and Human Services State Bureau: Maine Center for Disease Control & Prevention Federal Agency: U.S. Department of Health and Human Services Assistance Listing Title: Immunization Cooperative Agreements (COVID-19) Assistance Listing Number: 93.268 Federal Award Identification Number: NH23IP922604 Compliance Area: Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must: ? include Federal award information in the subaward that enables subrecipients to identify the source of the Federal award, as well as certain subrecipient information. ? evaluate each subrecipient?s risk of noncompliance with Federal regulations for the purposes of determining the appropriate level of subrecipient monitoring to be performed. ? monitor the activities of the subrecipient as necessary to ensure that subawards are used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward, and that subaward performance goals are achieved. Condition: The Department is responsible for ensuring subrecipients comply with Federal requirements by: ? reviewing subrecipient grant awards to ensure accurate Federal award identification information is included to allow subrecipients to accurately identify the source of the subawards; ? utilizing risk evaluations to determine the appropriate level of monitoring activities to be performed that correspond to the results of those risk evaluations; and ? performing ongoing monitoring activities to ensure that the subaward was used for authorized purposes and in compliance with Federal regulations. The Office of the State Auditor (OSA) tested compliance with subrecipient monitoring requirements for 7 subrecipients and found that: ? 3 subawards did not properly identify required Federal award information: o 2 subawards were missing the subrecipient?s Data Universal Numbering System (DUNS) number. o 2 subawards reported the wrong Assistance Listing Number. ? 2 subrecipients were deemed ?higher risk? after the Department performed a risk evaluation; however, the Department could not provide documentation to support that additional monitoring activities were performed in response to the ?higher risk? designation. ? 80 performance reports were required to be completed and submitted for fiscal year 2022 to ensure subaward performance goals are achieved. o 47 reports were provided to the auditor but lacked evidence of supervisory review. o 33 reports could not be provided. ? 52 financial reports were required to be completed and submitted for fiscal year 2022 to ensure subawards are used for approved budgeted expenditures. o 32 reports were provided to the auditor but lacked evidence of supervisory review. o 20 reports could not be provided. The Department could not provide any further documentation to support subrecipient monitoring procedures occurred during fiscal year 2022 to ensure that the subaward was used for authorized purposes. OSA selected a non-statistical random sample. Context: The Department provided $2.5 million to 35 Immunization Cooperative Agreements (ICA) program subrecipients in fiscal year 2022. Cause: ? Lack of adequate policies and procedures ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Lack of ongoing subrecipient monitoring procedures could result in undetected subrecipient noncompliance. Recommendation: We recommend that the Department implement policies and procedures to ensure that: ? subaward agreements include all required information and are accurate; ? risk evaluations are utilized to determine the appropriate level of monitoring activities to be performed; and ? ongoing subrecipient monitoring is completed during the subaward and documented. This will ensure that the Department is in compliance with subrecipient monitoring requirements. Corrective Action Plan: See F-22 Management?s Response: The Department agrees with this finding. The Department initiated these subrecipient agreements to ensure equitable access to COVID-19 vaccines. As a result of these agreements, Maine had one of the best vaccine roll-outs in the country, including among Black, Indigenous, and People of Color. Some of the information requested by OSA was unable to be accessed because it was saved in individual staff files which were moved when an employee was transferred or left employment with the Department. The Department will implement processes in SFY23 to improve record keeping for these subawards including: 1) reviewing subaward agreements using a checklist to ensure they include all the required information and are accurate; 2) ensuring that risk evaluations are utilized to determine the appropriate level of monitoring; and 3) improving and centralizing subrecipient monitoring documentation within the Office of Population Health Equity (OPHE) at Maine CDC. Contact: Ian Yaffe, Director, Office of Population Health Equity, DHHS, 207- 592-1481 (State Number: 22-1118-03)
(2022-071) Title: Internal control over TANF subrecipient risk evaluation procedures needs improvement Prior Year Findings: See Schedule of Findings and Questioned Costs for chart/table State Department: Health and Human Services State Bureau: Office for Family Independence Office of Child and Family Services Division of Contract Management Division of Audit Federal Agency: U.S. Department of Health and Human Services Assistance Listing Title: Temporary Assistance for Needy Families (TANF) (COVID-19) Assistance Listing Number: 93.558 Federal Award Identification Number: 1901METANF, 2001METANF, 2101METANF Compliance Area: Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department is required to 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 described in 2 CFR 200.332. Condition: The Department has established subrecipient monitoring procedures depending on whether the subaward is competitively bid or not. If a subaward is competitively bid, the Department seeks input from the Department of Health and Human Services Service Center, and the Department?s Division of Audit and Division of Contract Management regarding known issues with the provider who submitted the bid. Those responses are collected and provided to the evaluation team which consists of various program personnel. The subaward agreement is then drafted and the level of subrecipient monitoring is included in the agreement. If a subaward is not competitively bid, the subaward agreement is drafted based on the level of subrecipient monitoring that the Department has established for the provided services. The Office of the State Auditor (OSA) selected seven TANF subrecipients for testing and found: ? one subrecipient competitively bid on the subaward. The Department was able to provide evidence to support that feedback was solicited from other Bureaus for any known issues or prior noncompliance; however, documentary evidence could not be provided to support the level of subrecipient monitoring that was completed. ? six subrecipients did not competitively bid on the subaward. For those six subrecipients, no documentary evidence could be provided to support the level of subrecipient monitoring that was completed. OSA selected a non-statistical random sample. Context: The Department provided $17.9 million to TANF subrecipients during fiscal year 2022. Cause: Lack of adequate policies and procedures Effect: ? Without a documented process, subrecipient risk evaluation procedures may not be consistently followed, and documentation may not be adequately maintained. ? Subrecipients that are deemed higher risk may not be monitored on a more frequent basis. Conversely, subrecipients that are deemed lower risk may not be monitored on a less frequent basis, which would free resources and time to dedicate towards other higher risk subrecipients. Recommendation: We recommend that the Department: ? document procedures that outline the collaborative process with all Bureaus. ? implement policies and procedures that require evaluation of each subrecipient?s risk of noncompliance specifically for the purposes of determining the appropriate subrecipient monitoring to be performed. This will ensure subrecipients are monitored appropriately based on risk designation. Corrective Action Plan: See F-26 Management?s Response: The Department disagrees with this finding. The Department has subrecipient monitoring procedures for all of its subrecipients whether they were competitively bid or not. The first assessment of risk, as noted in the finding, is when a subaward is competitively bid. Secondly, another risk assessment built into the Maine Uniform Accounting and Auditing Practices for Community Agencies (MAAP) in which requires higher risk subrecipients to undergo a higher level of testing. Additionally, there are audit and review requirements at a much lower threshold than that of the Uniform Guidance (UG). Finally, the Social Service Unit of the Division of Audit performs a risk assessment and tests transactions for those subrecipients that have been determined to be higher risk. The Department?s subrecipient monitoring procedures ensures that we comply with the UG 200.332(d) Pass-through entity (PTE) monitoring of the subrecipient must include: 1) Review of financial and performance reports. 2) Following-up and ensuring that subrecipients take timely and appropriate action on all deficiencies. 3) Issues management decisions. 4) PTE is responsible for resolving audit findings specifically related to the subaward. Based on the Department?s MAAP rules we ensure we comply with UG 200.332(e). Depending on the PTE?s assessment of risk, the following tools may be useful: 1) Training and technical assistance. 2) On-site reviews. 3) Arranging for agreed upon procedures. The Department covers #3 by ensuring that all of our subrecipients have a requirement to submit to the Department a/an Audit, Review or Schedule of Expenditures of Department Awards (SEDA). Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075 Auditor?s Concluding Remarks: The Department has misinterpreted the Federal regulation cited in this finding. The Department has responded to 2 CFR 200.332(d), which identifies monitoring procedures to be conducted during the subrecipient award period. OSA audited compliance with this during-the-award monitoring requirement and did not identify deficiencies. The Federal regulation that the Department failed to meet is 2 CFR 200.332(b). This regulation identifies procedures to be performed prior to monitoring procedures in order to determine the level of monitoring required for each subrecipient. 2 CFR 200.332(b) states that the Department 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, which may include consideration of factors such as: ? the subrecipient?s prior experience with the same or similar subawards; ? 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; ? whether the subrecipient has new personnel or new or substantially changed systems; and ? the extent and results of Federal awarding agency monitoring. The Department did not provide any documentation to support that monitoring procedures performed were based on an evaluation of the subrecipient?s risk of noncompliance. The finding remains as stated. (State Number: 22-1111-05)
(2022-076) Title: Internal control over TANF subrecipient audit procedures needs improvement Prior Year Findings: See Schedule of Findings and Questioned Costs for chart/table State Department: Health and Human Services State Bureau: Division of Audit Federal Agency: U.S. Department of Health and Human Services Assistance Listing Title: Temporary Assistance for Needy Families (TANF) (COVID-19) Assistance Listing Number: 93.558 Federal Award Identification Number: 1901METANF, 2001METANF, 2101METANF Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited. Condition: The Department requires subrecipients to submit their Single Audit to the Department?s Division of Audit. The Division maintains a database to track when subrecipient Single Audit reports are due and ensures that they are received. The Office of the State Auditor (OSA) tested four TANF subrecipients that had a Single Audit due in fiscal year 2022 for compliance with Federal regulations and found that the Division did not obtain the Single Audit for one subrecipient. The Division could not provide documentation to support that they contacted the subrecipient when the Single Audit was late. OSA was able to confirm that the subrecipient did have a Single Audit as required. Context: A Single Audit was due in fiscal year 2022 for eight TANF subrecipients that received $28.2 million of Federal funds in fiscal year 2021. Cause: ? Lack of adequate procedures ? Lack of supervisory oversight Effect: Noncompliance with Federal regulations Recommendation: We recommend that the Department enhance existing procedures to ensure that subrecipients that expend $750,000 or more in Federal awards complete and submit a Single Audit within the required time requirements. Corrective Action Plan: See F-27 Management?s Response: The Department agrees with this finding. We will revise our standard operating procedures (SOP) to include the search for out of state subrecipients on the Federal Audit Clearinghouse. Contact: Herb Downs, Director, Division of Audit, DHHS, 207-287-2778 (State Number: 22-1100-02)
(2022-071) Title: Internal control over TANF subrecipient risk evaluation procedures needs improvement Prior Year Findings: See Schedule of Findings and Questioned Costs for chart/table State Department: Health and Human Services State Bureau: Office for Family Independence Office of Child and Family Services Division of Contract Management Division of Audit Federal Agency: U.S. Department of Health and Human Services Assistance Listing Title: Temporary Assistance for Needy Families (TANF) (COVID-19) Assistance Listing Number: 93.558 Federal Award Identification Number: 1901METANF, 2001METANF, 2101METANF Compliance Area: Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department is required to 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 described in 2 CFR 200.332. Condition: The Department has established subrecipient monitoring procedures depending on whether the subaward is competitively bid or not. If a subaward is competitively bid, the Department seeks input from the Department of Health and Human Services Service Center, and the Department?s Division of Audit and Division of Contract Management regarding known issues with the provider who submitted the bid. Those responses are collected and provided to the evaluation team which consists of various program personnel. The subaward agreement is then drafted and the level of subrecipient monitoring is included in the agreement. If a subaward is not competitively bid, the subaward agreement is drafted based on the level of subrecipient monitoring that the Department has established for the provided services. The Office of the State Auditor (OSA) selected seven TANF subrecipients for testing and found: ? one subrecipient competitively bid on the subaward. The Department was able to provide evidence to support that feedback was solicited from other Bureaus for any known issues or prior noncompliance; however, documentary evidence could not be provided to support the level of subrecipient monitoring that was completed. ? six subrecipients did not competitively bid on the subaward. For those six subrecipients, no documentary evidence could be provided to support the level of subrecipient monitoring that was completed. OSA selected a non-statistical random sample. Context: The Department provided $17.9 million to TANF subrecipients during fiscal year 2022. Cause: Lack of adequate policies and procedures Effect: ? Without a documented process, subrecipient risk evaluation procedures may not be consistently followed, and documentation may not be adequately maintained. ? Subrecipients that are deemed higher risk may not be monitored on a more frequent basis. Conversely, subrecipients that are deemed lower risk may not be monitored on a less frequent basis, which would free resources and time to dedicate towards other higher risk subrecipients. Recommendation: We recommend that the Department: ? document procedures that outline the collaborative process with all Bureaus. ? implement policies and procedures that require evaluation of each subrecipient?s risk of noncompliance specifically for the purposes of determining the appropriate subrecipient monitoring to be performed. This will ensure subrecipients are monitored appropriately based on risk designation. Corrective Action Plan: See F-26 Management?s Response: The Department disagrees with this finding. The Department has subrecipient monitoring procedures for all of its subrecipients whether they were competitively bid or not. The first assessment of risk, as noted in the finding, is when a subaward is competitively bid. Secondly, another risk assessment built into the Maine Uniform Accounting and Auditing Practices for Community Agencies (MAAP) in which requires higher risk subrecipients to undergo a higher level of testing. Additionally, there are audit and review requirements at a much lower threshold than that of the Uniform Guidance (UG). Finally, the Social Service Unit of the Division of Audit performs a risk assessment and tests transactions for those subrecipients that have been determined to be higher risk. The Department?s subrecipient monitoring procedures ensures that we comply with the UG 200.332(d) Pass-through entity (PTE) monitoring of the subrecipient must include: 1) Review of financial and performance reports. 2) Following-up and ensuring that subrecipients take timely and appropriate action on all deficiencies. 3) Issues management decisions. 4) PTE is responsible for resolving audit findings specifically related to the subaward. Based on the Department?s MAAP rules we ensure we comply with UG 200.332(e). Depending on the PTE?s assessment of risk, the following tools may be useful: 1) Training and technical assistance. 2) On-site reviews. 3) Arranging for agreed upon procedures. The Department covers #3 by ensuring that all of our subrecipients have a requirement to submit to the Department a/an Audit, Review or Schedule of Expenditures of Department Awards (SEDA). Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075 Auditor?s Concluding Remarks: The Department has misinterpreted the Federal regulation cited in this finding. The Department has responded to 2 CFR 200.332(d), which identifies monitoring procedures to be conducted during the subrecipient award period. OSA audited compliance with this during-the-award monitoring requirement and did not identify deficiencies. The Federal regulation that the Department failed to meet is 2 CFR 200.332(b). This regulation identifies procedures to be performed prior to monitoring procedures in order to determine the level of monitoring required for each subrecipient. 2 CFR 200.332(b) states that the Department 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, which may include consideration of factors such as: ? the subrecipient?s prior experience with the same or similar subawards; ? 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; ? whether the subrecipient has new personnel or new or substantially changed systems; and ? the extent and results of Federal awarding agency monitoring. The Department did not provide any documentation to support that monitoring procedures performed were based on an evaluation of the subrecipient?s risk of noncompliance. The finding remains as stated. (State Number: 22-1111-05)
(2022-076) Title: Internal control over TANF subrecipient audit procedures needs improvement Prior Year Findings: See Schedule of Findings and Questioned Costs for chart/table State Department: Health and Human Services State Bureau: Division of Audit Federal Agency: U.S. Department of Health and Human Services Assistance Listing Title: Temporary Assistance for Needy Families (TANF) (COVID-19) Assistance Listing Number: 93.558 Federal Award Identification Number: 1901METANF, 2001METANF, 2101METANF Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited. Condition: The Department requires subrecipients to submit their Single Audit to the Department?s Division of Audit. The Division maintains a database to track when subrecipient Single Audit reports are due and ensures that they are received. The Office of the State Auditor (OSA) tested four TANF subrecipients that had a Single Audit due in fiscal year 2022 for compliance with Federal regulations and found that the Division did not obtain the Single Audit for one subrecipient. The Division could not provide documentation to support that they contacted the subrecipient when the Single Audit was late. OSA was able to confirm that the subrecipient did have a Single Audit as required. Context: A Single Audit was due in fiscal year 2022 for eight TANF subrecipients that received $28.2 million of Federal funds in fiscal year 2021. Cause: ? Lack of adequate procedures ? Lack of supervisory oversight Effect: Noncompliance with Federal regulations Recommendation: We recommend that the Department enhance existing procedures to ensure that subrecipients that expend $750,000 or more in Federal awards complete and submit a Single Audit within the required time requirements. Corrective Action Plan: See F-27 Management?s Response: The Department agrees with this finding. We will revise our standard operating procedures (SOP) to include the search for out of state subrecipients on the Federal Audit Clearinghouse. Contact: Herb Downs, Director, Division of Audit, DHHS, 207-287-2778 (State Number: 22-1100-02)
Assistance Listing Number, Federal Agency, and Program Name - 14.241, U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332(b) and (d), 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 and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward and that subaward performance goals are achieved. Condition - The City did not perform a risk assessment of the subrecipient during the year and did not maintain documentation of subrecipient monitoring as evidence to support subrecipient monitoring performed. Questioned Costs - Unknown Identification of How Questioned Costs Were Computed - N/A Context - The City has a policy in place that it must perform an annual risk assessment of each subrecipient and guidelines for how to perform subrecipient monitoring. The City has one subrecipient that received HOPWA funding, and the City did not perform the required annual risk assessments for this subrecipient. Cause and Effect - The City did not have adequate controls to ensure its policies related to subrecipient monitoring were followed, resulting in inadequate monitoring of subrecipients. Recommendation - The City should ensure that policies on internal controls and processes adequately address the requirements and are complied with. Views of Responsible Officials and Corrective Action Plan - The City agrees with the finding and will put procedures in place to ensure appropriate documentation is retained related to subrecipient monitoring and comply with the relevant internal policies.
Assistance Listing Number, Federal Agency, and Program Name - 14.241, U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332(b) and (d), 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 and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward and that subaward performance goals are achieved. Condition - The City did not perform a risk assessment of the subrecipient during the year and did not maintain documentation of subrecipient monitoring as evidence to support subrecipient monitoring performed. Questioned Costs - Unknown Identification of How Questioned Costs Were Computed - N/A Context - The City has a policy in place that it must perform an annual risk assessment of each subrecipient and guidelines for how to perform subrecipient monitoring. The City has one subrecipient that received HOPWA funding, and the City did not perform the required annual risk assessments for this subrecipient. Cause and Effect - The City did not have adequate controls to ensure its policies related to subrecipient monitoring were followed, resulting in inadequate monitoring of subrecipients. Recommendation - The City should ensure that policies on internal controls and processes adequately address the requirements and are complied with. Views of Responsible Officials and Corrective Action Plan - The City agrees with the finding and will put procedures in place to ensure appropriate documentation is retained related to subrecipient monitoring and comply with the relevant internal policies.
Assistance Listing Number, Federal Agency, and Program Name - 14.241, U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332(b) and (d), 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 and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward and that subaward performance goals are achieved. Condition - The City did not perform a risk assessment of the subrecipient during the year and did not maintain documentation of subrecipient monitoring as evidence to support subrecipient monitoring performed. Questioned Costs - Unknown Identification of How Questioned Costs Were Computed - N/A Context - The City has a policy in place that it must perform an annual risk assessment of each subrecipient and guidelines for how to perform subrecipient monitoring. The City has one subrecipient that received HOPWA funding, and the City did not perform the required annual risk assessments for this subrecipient. Cause and Effect - The City did not have adequate controls to ensure its policies related to subrecipient monitoring were followed, resulting in inadequate monitoring of subrecipients. Recommendation - The City should ensure that policies on internal controls and processes adequately address the requirements and are complied with. Views of Responsible Officials and Corrective Action Plan - The City agrees with the finding and will put procedures in place to ensure appropriate documentation is retained related to subrecipient monitoring and comply with the relevant internal policies.
Assistance Listing Number, Federal Agency, and Program Name - 14.241, U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332(b) and (d), 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 and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward and that subaward performance goals are achieved. Condition - The City did not perform a risk assessment of the subrecipient during the year and did not maintain documentation of subrecipient monitoring as evidence to support subrecipient monitoring performed. Questioned Costs - Unknown Identification of How Questioned Costs Were Computed - N/A Context - The City has a policy in place that it must perform an annual risk assessment of each subrecipient and guidelines for how to perform subrecipient monitoring. The City has one subrecipient that received HOPWA funding, and the City did not perform the required annual risk assessments for this subrecipient. Cause and Effect - The City did not have adequate controls to ensure its policies related to subrecipient monitoring were followed, resulting in inadequate monitoring of subrecipients. Recommendation - The City should ensure that policies on internal controls and processes adequately address the requirements and are complied with. Views of Responsible Officials and Corrective Action Plan - The City agrees with the finding and will put procedures in place to ensure appropriate documentation is retained related to subrecipient monitoring and comply with the relevant internal policies.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirements: Activities allowed or unallowed and allowable costs/cost principles Questioned costs: $25,761 Condition?Contrary to federal regulations and grantor and County policies and procedures, the County?s Workforce Innovation and Opportunity Act (WIOA) Department (Department) spent $25,761 of WIOA program monies for unallowable purposes. Specifically, we found that the Department paid for unallowable purchases and invoices of a third-party nonprofit organization that the Department?s former director helped create while employed by the County and that the County had contracted with to increase the capacity of the local workforce system. Despite the contract between the County and the nonprofit organization not authorizing the nonprofit organization to obligate the County for its expenses or enter into agreements on the County?s behalf, both occurred. The $25,761 of unallowable purchases included: ? $25,431 for the nonprofit organization?s leased building ($18,700), electronic data services ($3,545), utilities invoices ($2,951), and a storage unit ($235). ? $260 for purchases made using County purchasing cards, consisting of gift cards, food and beverages, and board games, $245 of which were for the nonprofit organization?s program outreach activities but not allowed by the program?s requirements or the County?s purchasing card policies and procedures. ? $70 for other purchases made using County purchasing cards that the Department charged to the program but did not have documentation to support their allowability. Effect?The Department received federal reimbursement for $25,761 in unallowable charges it made to the program that it was not eligible to receive and, therefore, is at risk of having to return these monies to the pass-through grantor.1 Further, the Department made $25,761 of grant monies unavailable for their intended purpose. Cause?The County?s lack of internal controls and former WIOA director?s inadequate oversight of the WIOA program contributed to the Department?s spending of WIOA program monies for unallowable purposes. Specifically, the County?s policies and procedures did not include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. This, combined with the former WIOA director?s comingling of the nonprofit organization?s financial activities, contributed to the Department directly paying for purchases and invoices belonging to the nonprofit organization despite them not being invoiced to or addressed to the County. In addition, Department staff reported that they believed the nonprofit organization?s purchases and invoices were allowable for the County to pay for and charge to the program; however, they did not maintain documentation to support this justification. Further, the former WIOA director did not provide proper oversight and ensure that the Department followed federal regulations and grantor and County policies and procedures to incur and pay for or reimburse only authorized federal program costs and to maintain documentation to support that the County?s program costs were allowable. Criteria?Federal regulations require the Department to reimburse only those federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements (2 CFR 200.403). The grantor and County policies and procedures contain similar requirements and also require the Department to retain records and other documentation supporting the County?s administration of federal awards for at least 3 years (Navajo County. [2019]. Fiscal Policy Manual, Section 4.4 ).2 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County should: 1. Improve its accounts payable policies and procedures to include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. 2. Follow federal regulations and grantor and County policies and procedures requiring it to: a. Incur and pay for or reimburse only authorized federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements. b. Maintain documentation to support that federal program costs it incurs and pays for or reimburses are allowable. 3. Verify all invoices belong to and are addressed to the County prior to payment. 4. Ensure that the Department establishes clear contractual arrangements with entities the Department plans to use to help administer the federal program that comply with County policies and procedures and the program?s requirements. 5. Coordinate with the pass-through grantor to adjust future federal reimbursements requests or repay the pass-through grantor for the unallowable costs the Department charged to the program. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Arizona Department of Economic Security. (n.d.). Workforce Innovation and Opportunity Act Policy Manual. Retrieved on 3/1/2023 from https://des.az.gov/services/employment/workforce-innovation-and-opportunity-act-wioa/title-i-b-policy-and-procedure 2 Federal Uniform Guidance requires the pass-through entities to follow up, issue management decisions, and resolve subrecipients single audit findings as part of their monitoring responsibilities for ensuring that subawards are used for authorized purposes, in compliance with federal laws and regulations and the award terms, and that the program?s performance goals are achieved (2 CFR ?200.332[d]).
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirements: Activities allowed or unallowed and allowable costs/cost principles Questioned costs: $25,761 Condition?Contrary to federal regulations and grantor and County policies and procedures, the County?s Workforce Innovation and Opportunity Act (WIOA) Department (Department) spent $25,761 of WIOA program monies for unallowable purposes. Specifically, we found that the Department paid for unallowable purchases and invoices of a third-party nonprofit organization that the Department?s former director helped create while employed by the County and that the County had contracted with to increase the capacity of the local workforce system. Despite the contract between the County and the nonprofit organization not authorizing the nonprofit organization to obligate the County for its expenses or enter into agreements on the County?s behalf, both occurred. The $25,761 of unallowable purchases included: ? $25,431 for the nonprofit organization?s leased building ($18,700), electronic data services ($3,545), utilities invoices ($2,951), and a storage unit ($235). ? $260 for purchases made using County purchasing cards, consisting of gift cards, food and beverages, and board games, $245 of which were for the nonprofit organization?s program outreach activities but not allowed by the program?s requirements or the County?s purchasing card policies and procedures. ? $70 for other purchases made using County purchasing cards that the Department charged to the program but did not have documentation to support their allowability. Effect?The Department received federal reimbursement for $25,761 in unallowable charges it made to the program that it was not eligible to receive and, therefore, is at risk of having to return these monies to the pass-through grantor.1 Further, the Department made $25,761 of grant monies unavailable for their intended purpose. Cause?The County?s lack of internal controls and former WIOA director?s inadequate oversight of the WIOA program contributed to the Department?s spending of WIOA program monies for unallowable purposes. Specifically, the County?s policies and procedures did not include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. This, combined with the former WIOA director?s comingling of the nonprofit organization?s financial activities, contributed to the Department directly paying for purchases and invoices belonging to the nonprofit organization despite them not being invoiced to or addressed to the County. In addition, Department staff reported that they believed the nonprofit organization?s purchases and invoices were allowable for the County to pay for and charge to the program; however, they did not maintain documentation to support this justification. Further, the former WIOA director did not provide proper oversight and ensure that the Department followed federal regulations and grantor and County policies and procedures to incur and pay for or reimburse only authorized federal program costs and to maintain documentation to support that the County?s program costs were allowable. Criteria?Federal regulations require the Department to reimburse only those federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements (2 CFR 200.403). The grantor and County policies and procedures contain similar requirements and also require the Department to retain records and other documentation supporting the County?s administration of federal awards for at least 3 years (Navajo County. [2019]. Fiscal Policy Manual, Section 4.4 ).2 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County should: 1. Improve its accounts payable policies and procedures to include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. 2. Follow federal regulations and grantor and County policies and procedures requiring it to: a. Incur and pay for or reimburse only authorized federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements. b. Maintain documentation to support that federal program costs it incurs and pays for or reimburses are allowable. 3. Verify all invoices belong to and are addressed to the County prior to payment. 4. Ensure that the Department establishes clear contractual arrangements with entities the Department plans to use to help administer the federal program that comply with County policies and procedures and the program?s requirements. 5. Coordinate with the pass-through grantor to adjust future federal reimbursements requests or repay the pass-through grantor for the unallowable costs the Department charged to the program. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Arizona Department of Economic Security. (n.d.). Workforce Innovation and Opportunity Act Policy Manual. Retrieved on 3/1/2023 from https://des.az.gov/services/employment/workforce-innovation-and-opportunity-act-wioa/title-i-b-policy-and-procedure 2 Federal Uniform Guidance requires the pass-through entities to follow up, issue management decisions, and resolve subrecipients single audit findings as part of their monitoring responsibilities for ensuring that subawards are used for authorized purposes, in compliance with federal laws and regulations and the award terms, and that the program?s performance goals are achieved (2 CFR ?200.332[d]).
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirements: Activities allowed or unallowed and allowable costs/cost principles Questioned costs: $25,761 Condition?Contrary to federal regulations and grantor and County policies and procedures, the County?s Workforce Innovation and Opportunity Act (WIOA) Department (Department) spent $25,761 of WIOA program monies for unallowable purposes. Specifically, we found that the Department paid for unallowable purchases and invoices of a third-party nonprofit organization that the Department?s former director helped create while employed by the County and that the County had contracted with to increase the capacity of the local workforce system. Despite the contract between the County and the nonprofit organization not authorizing the nonprofit organization to obligate the County for its expenses or enter into agreements on the County?s behalf, both occurred. The $25,761 of unallowable purchases included: ? $25,431 for the nonprofit organization?s leased building ($18,700), electronic data services ($3,545), utilities invoices ($2,951), and a storage unit ($235). ? $260 for purchases made using County purchasing cards, consisting of gift cards, food and beverages, and board games, $245 of which were for the nonprofit organization?s program outreach activities but not allowed by the program?s requirements or the County?s purchasing card policies and procedures. ? $70 for other purchases made using County purchasing cards that the Department charged to the program but did not have documentation to support their allowability. Effect?The Department received federal reimbursement for $25,761 in unallowable charges it made to the program that it was not eligible to receive and, therefore, is at risk of having to return these monies to the pass-through grantor.1 Further, the Department made $25,761 of grant monies unavailable for their intended purpose. Cause?The County?s lack of internal controls and former WIOA director?s inadequate oversight of the WIOA program contributed to the Department?s spending of WIOA program monies for unallowable purposes. Specifically, the County?s policies and procedures did not include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. This, combined with the former WIOA director?s comingling of the nonprofit organization?s financial activities, contributed to the Department directly paying for purchases and invoices belonging to the nonprofit organization despite them not being invoiced to or addressed to the County. In addition, Department staff reported that they believed the nonprofit organization?s purchases and invoices were allowable for the County to pay for and charge to the program; however, they did not maintain documentation to support this justification. Further, the former WIOA director did not provide proper oversight and ensure that the Department followed federal regulations and grantor and County policies and procedures to incur and pay for or reimburse only authorized federal program costs and to maintain documentation to support that the County?s program costs were allowable. Criteria?Federal regulations require the Department to reimburse only those federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements (2 CFR 200.403). The grantor and County policies and procedures contain similar requirements and also require the Department to retain records and other documentation supporting the County?s administration of federal awards for at least 3 years (Navajo County. [2019]. Fiscal Policy Manual, Section 4.4 ).2 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County should: 1. Improve its accounts payable policies and procedures to include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. 2. Follow federal regulations and grantor and County policies and procedures requiring it to: a. Incur and pay for or reimburse only authorized federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements. b. Maintain documentation to support that federal program costs it incurs and pays for or reimburses are allowable. 3. Verify all invoices belong to and are addressed to the County prior to payment. 4. Ensure that the Department establishes clear contractual arrangements with entities the Department plans to use to help administer the federal program that comply with County policies and procedures and the program?s requirements. 5. Coordinate with the pass-through grantor to adjust future federal reimbursements requests or repay the pass-through grantor for the unallowable costs the Department charged to the program. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Arizona Department of Economic Security. (n.d.). Workforce Innovation and Opportunity Act Policy Manual. Retrieved on 3/1/2023 from https://des.az.gov/services/employment/workforce-innovation-and-opportunity-act-wioa/title-i-b-policy-and-procedure 2 Federal Uniform Guidance requires the pass-through entities to follow up, issue management decisions, and resolve subrecipients single audit findings as part of their monitoring responsibilities for ensuring that subawards are used for authorized purposes, in compliance with federal laws and regulations and the award terms, and that the program?s performance goals are achieved (2 CFR ?200.332[d]).
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Child Nutrition Cluster program prior to February of 2021. CRITERIA 31 U.S.C. 7502(f)(2)(A) states that each pass-through entity shall provide subrecipient the Federal requirements which govern the use of such awards. 2 CFR 200.332 states the required information that pass-through entities must disclose. This includes information related to Federal award identification, requirements imposed by the pass-through entity on the subrecipient, any additional requirements, approved federally recognized indirect cost rate, requirement that the subrecipient allow access to records, and appropriate terms and conditions concerning closeout of the subaward. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The prior audit finding corrective action wasn't implemented until February of 2021. Therefore, the grant templates were still missing information as was documented during the 2019-2020 single audit. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT During our audit period, there were 412 subrecipients receiving Federal grant agreements for the Child Nutrition Cluster program. During 2021, there were 215 subrecipients and 197 in 2022. As there was a similar finding in our prior audit that was not implemented until February of 2021, only grants obligated after this date and before the end of our audit period of 6/30/2022 were considered in our testing. Grants made prior to February 2021 were considered to have missing information. During our testing, no missing information was noted in grants made after February 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2020-022 was reported in the immediate prior year. Finding 2018-042 and 2016-068 were made in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction continue the corrective action that was implemented in February of 2021 to ensure subrecipients are made aware of all required grant award information for the Child Nutrition Cluster program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Child Nutrition Cluster program prior to February of 2021. CRITERIA 31 U.S.C. 7502(f)(2)(A) states that each pass-through entity shall provide subrecipient the Federal requirements which govern the use of such awards. 2 CFR 200.332 states the required information that pass-through entities must disclose. This includes information related to Federal award identification, requirements imposed by the pass-through entity on the subrecipient, any additional requirements, approved federally recognized indirect cost rate, requirement that the subrecipient allow access to records, and appropriate terms and conditions concerning closeout of the subaward. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The prior audit finding corrective action wasn't implemented until February of 2021. Therefore, the grant templates were still missing information as was documented during the 2019-2020 single audit. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT During our audit period, there were 412 subrecipients receiving Federal grant agreements for the Child Nutrition Cluster program. During 2021, there were 215 subrecipients and 197 in 2022. As there was a similar finding in our prior audit that was not implemented until February of 2021, only grants obligated after this date and before the end of our audit period of 6/30/2022 were considered in our testing. Grants made prior to February 2021 were considered to have missing information. During our testing, no missing information was noted in grants made after February 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2020-022 was reported in the immediate prior year. Finding 2018-042 and 2016-068 were made in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction continue the corrective action that was implemented in February of 2021 to ensure subrecipients are made aware of all required grant award information for the Child Nutrition Cluster program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Child and Adult Care Food program prior to February of 2021. CRITERIA 31 U.S.C. 7502(f)(2)(A) states that each pass-through entity shall provide subrecipient the Federal requirements which govern the use of such awards. 2 CFR 200.332 states the required information that pass-through entities must disclose. This includes information related to Federal award identification, requirements imposed by the pass-through entity on the subrecipient, any additional requirements, approved federally recognized indirect cost rate, requirement that the subrecipient allow access to records, and appropriate terms and conditions concerning closeout of the subaward. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The prior audit finding corrective action wasn't implemented until February of 2021. Therefore, grant templates were still missing information as was documented during the 2019-2020 single audit. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT During our audit period, there were 236 subrecipients receiving Federal grant agreements for the Child and Adult Care Food program. During 2021, there were 126 subrecipients and 110 in 2022. As there was a similar finding in our prior audit that was not implemented until February of 2021, only grants obligated after this date and before the end of our audit period of 6/30/2022 were considered in our testing. Grants made prior to February of 2021 were considered to have missing information. During our testing, no missing information was noted in grants made after February of 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2020-022 was reported in the immediate prior year. Finding 2018-042 and 2016-068 were made in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction continue the corrective action that was implemented in February of 2021 to ensure subrecipients are made aware of all required grant award information for the Child and Adult Care Food program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Child Nutrition Cluster program prior to February of 2021. CRITERIA 31 U.S.C. 7502(f)(2)(A) states that each pass-through entity shall provide subrecipient the Federal requirements which govern the use of such awards. 2 CFR 200.332 states the required information that pass-through entities must disclose. This includes information related to Federal award identification, requirements imposed by the pass-through entity on the subrecipient, any additional requirements, approved federally recognized indirect cost rate, requirement that the subrecipient allow access to records, and appropriate terms and conditions concerning closeout of the subaward. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The prior audit finding corrective action wasn't implemented until February of 2021. Therefore, the grant templates were still missing information as was documented during the 2019-2020 single audit. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT During our audit period, there were 412 subrecipients receiving Federal grant agreements for the Child Nutrition Cluster program. During 2021, there were 215 subrecipients and 197 in 2022. As there was a similar finding in our prior audit that was not implemented until February of 2021, only grants obligated after this date and before the end of our audit period of 6/30/2022 were considered in our testing. Grants made prior to February 2021 were considered to have missing information. During our testing, no missing information was noted in grants made after February 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2020-022 was reported in the immediate prior year. Finding 2018-042 and 2016-068 were made in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction continue the corrective action that was implemented in February of 2021 to ensure subrecipients are made aware of all required grant award information for the Child Nutrition Cluster program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Child Nutrition Cluster program prior to February of 2021. CRITERIA 31 U.S.C. 7502(f)(2)(A) states that each pass-through entity shall provide subrecipient the Federal requirements which govern the use of such awards. 2 CFR 200.332 states the required information that pass-through entities must disclose. This includes information related to Federal award identification, requirements imposed by the pass-through entity on the subrecipient, any additional requirements, approved federally recognized indirect cost rate, requirement that the subrecipient allow access to records, and appropriate terms and conditions concerning closeout of the subaward. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The prior audit finding corrective action wasn't implemented until February of 2021. Therefore, the grant templates were still missing information as was documented during the 2019-2020 single audit. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT During our audit period, there were 412 subrecipients receiving Federal grant agreements for the Child Nutrition Cluster program. During 2021, there were 215 subrecipients and 197 in 2022. As there was a similar finding in our prior audit that was not implemented until February of 2021, only grants obligated after this date and before the end of our audit period of 6/30/2022 were considered in our testing. Grants made prior to February 2021 were considered to have missing information. During our testing, no missing information was noted in grants made after February 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2020-022 was reported in the immediate prior year. Finding 2018-042 and 2016-068 were made in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction continue the corrective action that was implemented in February of 2021 to ensure subrecipients are made aware of all required grant award information for the Child Nutrition Cluster program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Child Nutrition Cluster program prior to February of 2021. CRITERIA 31 U.S.C. 7502(f)(2)(A) states that each pass-through entity shall provide subrecipient the Federal requirements which govern the use of such awards. 2 CFR 200.332 states the required information that pass-through entities must disclose. This includes information related to Federal award identification, requirements imposed by the pass-through entity on the subrecipient, any additional requirements, approved federally recognized indirect cost rate, requirement that the subrecipient allow access to records, and appropriate terms and conditions concerning closeout of the subaward. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The prior audit finding corrective action wasn't implemented until February of 2021. Therefore, the grant templates were still missing information as was documented during the 2019-2020 single audit. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT During our audit period, there were 412 subrecipients receiving Federal grant agreements for the Child Nutrition Cluster program. During 2021, there were 215 subrecipients and 197 in 2022. As there was a similar finding in our prior audit that was not implemented until February of 2021, only grants obligated after this date and before the end of our audit period of 6/30/2022 were considered in our testing. Grants made prior to February 2021 were considered to have missing information. During our testing, no missing information was noted in grants made after February 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2020-022 was reported in the immediate prior year. Finding 2018-042 and 2016-068 were made in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction continue the corrective action that was implemented in February of 2021 to ensure subrecipients are made aware of all required grant award information for the Child Nutrition Cluster program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not complete a risk assessment for any awards to subrecipients of the Supporting Effective Instruction program during the audit period. CRITERIA 2 CFR 200.332 ? states that all pass-through entities must: (b) 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. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The Department of Public Instruction overlooked completing subrecipient risk assessments due to the continued response of the COVID-19 pandemic. EFFECT Department of Public Instruction is not able to verify that subrecipients are compliant with Federal statutes, regulations, and terms and conditions of the subaward because there was no risk assessment completed for subrecipients in order to determine appropriate monitoring. CONTEXT The Department of Public Instruction distributed approximately $19,000,000 in Federal funds under the Supporting Effective Instruction program to 168 different subrecipients. While these subrecipients did receive monitoring procedures, no adjustments were made to individual subrecipients based on the results of risk assessments. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Department of Public Instruction ensure subrecipient risk assessments are completed timely and used to determine the nature and extent of subrecipient monitoring for the Supporting Effective Instruction program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not complete any risk assessments for 3 of 5 subrecipients sampled and only completed a risk assessment once during our audit period for the other 2 sampled even though they received separate grants during each fiscal year. CRITERIA 2 CFR 200.332 (b) states "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 described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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 in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency)." Department of Public Instruction awarded grants to subrecipients annually under this program. As such, a risk assessment should be completed annually for each subrecipient in which a new grant was awarded to them. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The Department of Public Instruction did not complete risk assessments for subrecipients as the Comprehensive Literacy program had a high turnover of staff that were administering the program and the Department did not have this responsibility assigned to someone during parts of our audit period. EFFECT The Department of Public Instruction is not adjusting their subrecipient monitoring based on risk assessments completed for the subrecipients in compliance with Federal regulations. CONTEXT The Department of Public Instruction distributed approximately $23,250,000 in Federal funds under the Comprehensive Literacy program to 25 different local education agency subrecipients. While these subrecipients did receive monitoring procedures no adjustments were made to individual subrecipients based on results of risk assessments. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Department of Public Instruction ensure risk assessments are completed for each grant their subrecipients receive and adjust monitoring procedures as necessary based on the results of these assessments. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Comprehensive Literacy program as all grant templates used did not include the subaward budget period start and end date. CRITERIA 2 CFR 200.332 states required information that pass-through entities must disclose to subrecipients, including paragraph (a)(1)(vi) "Subaward Budget Period State and End Date" 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The Comprehensive Literacy Program did not update their grant templates to include a new requirement that was added to the relevant Federal codes and went into effect January 1, 2021. EFFECT Subrecipients may not have been made aware of all necessary grant information and requirements. CONTEXT The Comprehensively Literacy program grants subawards annually under each of the Federal grants it received under the program. During our audit period, there were 2 Federal awards granted out to subrecipients a total of 35 times each fiscal year. The grant agreements shared a template each year and it was found that all were missing a newly required piece of information after the relevant CFR was modified and an update went into effect on January 1, 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Department of Public Instruction ensure that subrecipients are made aware of all required grant award information. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Health did not ensure all required grant award information for Coronavirus Relief Funds (CRF) was provided to subrecipients. In addition, the Department's internal controls were insufficient to ensure that subrecipients received communication regarding the necessary items. Required information not communicated included: ? Subrecipient's unique entity identifier, ? Federal Award Identification Number, ? Total amount of Federal funds obligated to the subrecipient by the pass-through entity including the current financial obligation, ? Name of awarding agency, ? Assistance Listing Number; and, ? Indirect cost rate for Federal award including if the de minimis rate is charged. CRITERIA Federal regulation, 2 CFR 200.332(a), requires pass-through entities to communicate specific required information to subrecipients. Federal regulation, 2 CFR 200.303, requires non-Federal entities, in part, to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The Department of Health did not utilize its traditional grant template agreement to extend CRF dollars to ambulance, fire, school districts, and hospitals. Instead, the Department used a CARES Act Coronavirus Relief Fund Eligibility Certification form which did not contain all required items. EFFECT These required communications are intended to help subrecipients meet all their reporting requirements and to meet all award terms. Subrecipients subject to Single Audits also need this information for their audits. CONTEXT The Department of Health utilized its traditional grant template agreement for $31.7 million in grants provided to 28 local public health units which included the best information available to describe the Federal award and subaward. However, the Department did not utilize its traditional grant template agreement to extend up to $29.8 million of CRF dollars to 121 other entities, including ambulance, fire, and school districts and hospitals. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Department of Health: A) Communicate all required information of 2 CFR 200.332(a) to subrecipients. B) Develop procedures to ensure that all Coronavirus Relief Fund award information is communicated to subrecipients. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly Department of Health) agrees with the recommendation. See ?Management?s Response and Corrective Action? section of this report.