Condition: During the fiscal year ended June 30, 2024, the District was unable to provide a report that supported the accuracy of the verification report sample. This lack of documentation prevented us from verifying that the sample was appropriately selected and representative of the population, as required under federal regulations. Effect: The inability to confirm the accuracy and validity of the verification report sample compromises the reliability of compliance testing results. This creates a risk of noncompliance with federal program requirements and potential misreporting. Cause: The District transitioned to new software during the fiscal year and relied on the software to produce the sample without verifying the accuracy of the population data. Staff lacked an understanding of how the software selected samples and did not independently validate the sampling process. Criteria: Per 2 CFR § 200.333 (Retention requirements for records), recipients of federal awards must maintain adequate documentation to support financial and compliance-related activities. Additionally, accurate and reliable sampling procedures are critical for compliance with federal program requirements. Questioned Costs: None Recommendation: We recommend that the District implement a record retention policy that requires all supporting documentation for verification reports and samples to be maintained and reviewed for accuracy. We recommend that the District provide training to staff responsible for federal program compliance, emphasizing the importance of verifying population data and sampling processes. Obtain training from the software provider to ensure staff understand how the software generates samples and verify its accuracy. Establish a process for periodic internal reviews to confirm that all required documentation is retained and readily available for audit purposes. Management Response: This finding was also reported as Finding 2024-001 in the prior year’s audit. The District agrees with the finding as it was issued after verification for year ending June 30, 2025 had been completed. The District will be conducting manual verification for the year ending June 30, 2026 and forward to resolve the finding.
FINDING 2024-001 Subject: Highway Planning and Construction - Procurement Federal Agency: Department of Transportation Federal Program: Highway Planning and Construction Assistance Listings Number: 20.205 Federal Award Numbers and Years (or Other Identifying Numbers): DES. Nos. 1600968, 1702753, 1802927, 1802929, 1902066, 2301613 Pass-Through Entity: Indiana Department of Transportation Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context Recipients may use award funds to procure engineering and design-related services from consultants necessary to implement one or more eligible purposes outlined for the Highway Planning and Construction award funds. Subrecipients may adopt written policies and procedures prescribed by the awarding state DOT or prepare their own written policies and procedures approved by the Indiana Department of Transportation. The County did not have documented procurement procedures or policies used to procure engineering and design services. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 23 CFR 175 states in part: ". . . (b) Subrecipient responsibilities. Subrecipients shall develop and sustain organizational capacity and provide the resources necessary for the procurement, management, and administration of engineering and design related consultant services, reimbursed in whole or in part with FAHP funding as specified in 23 U.S.C. 106(g)(4)(A). Responsibilities shall include the following: (1) Adopting written policies and procedures prescribed by the awarding STA or other recipient for the procurement, management, and administration of engineering and design related consultant services in accordance with applicable Federal and State laws and regulations; or when not prescribed, shall include: (i) Preparing and maintaining its own written policies and procedures in accordance with paragraph (c) of this section; or (ii) Submitting documentation associated with each procurement and subsequent contract to the awarding STA or other grantee for review to assess compliance with applicable Federal and State laws, regulations, and the requirements of this part; (2) Procuring, managing, and administering engineering and design related consultant services in accordance with applicable Federal and State laws, regulations, and approved policies and procedures, as specified in 23 CFR 1.9(a). INDIANA STATE BOARD OF ACCOUNTS 14 RUSH COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (c) Written policies and procedures. The contracting agency shall prepare and maintain written policies and procedures for the procurement, management, and administration of engineering and design related consultant services. The FHWA shall approve the written policies and procedures, including all revisions to such policies and procedures, of the STA or recipient to assess compliance with applicable requirements. The STA or other recipient shall approve the written policies and procedures, including all revisions to such policies and procedures, of a subrecipient to assess compliance with applicable requirements. These policies and procedures shall address, as appropriate for each method of procurement a contracting agency proposes to use, the following items to ensure compliance with Federal and State laws, regulations, and the requirements of this part: (1) Preparing a scope of work and evaluation factors for the ranking/selection of a consultant; (2) Soliciting interests, qualifications, or proposals from prospective consultants; (3) Preventing, identifying, and mitigating conflicts of interest for employees of both the contracting agency and consultants and promptly disclosing in writing any potential conflict to the STA and FHWA, as specified in 2 CFR 200.112 and 23 CFR 1.33, and the requirements of this part. (4) Verifying suspension and debarment actions and eligibility of consultants, as specified in 2 CFR part 1200 and 2 CFR part 180; (5) Evaluating interests, qualifications, or proposals and the ranking/selection of a consultant; (6) Determining, based upon State procedures and the size and complexity of a project, the need for additional discussions following RFP submission and evaluation; (7) Preparing an independent agency estimate for use in negotiation with the selected consultant; (8) Selecting appropriate contract type, payment method, and terms and incorporating required contract provisions, assurances, and certifications in accordance with § 172.9; (9) Negotiating a contract with the selected consultant including instructions for proper disposal of concealed cost proposals of unsuccessful bidders; (10) Establishing elements of contract costs, accepting indirect cost rate(s) for application to contracts, and assuring consultant compliance with the Federal cost principles in accordance with § 172.11; (11) Ensuring consultant costs billed are allowable in accordance with the Federal cost principles and consistent with the contract terms as well as the acceptability and progress of the consultant's work; (12) Monitoring the consultant's work and compliance with the terms, conditions, and specifications of the contract; (13) Preparing a consultant's performance evaluation when services are completed and using such performance data in future evaluation and ranking of consultant to provide similar services; INDIANA STATE BOARD OF ACCOUNTS 15 RUSH COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (14) Closing-out a contract; (15) Retaining supporting programmatic and contract records, as specified in 2 CFR 200.333 and the requirements of this part; (16) Determining the extent to which the consultant, which is responsible for the professional quality, technical accuracy, and coordination of services, may be reasonably liable for costs resulting from errors and omissions in the work furnished under its contract; (17) Assessing administrative, contractual, or legal remedies in instances where consultants violate or breach contract terms and conditions, and providing for such sanctions and penalties as may be appropriate; and (18) Resolving disputes in the procurement, management, and administration of engineering and design related consultant services. (d) A contracting agency may formally adopt, by statute or within approved written policies and procedures as specified in paragraph (c) of this section, any direct Federal Government or other contracting regulation, standard, or procedure provided its application does not conflict with the provisions of 23 U.S.C. 112, the requirements of this part, and other laws and regulations applicable to the FAHP. (e) Notwithstanding paragraph (d) of this section, a contracting agency shall have a reasonable period of time, not to exceed 12 months from the effective date of this rule unless an extension is granted for unique or extenuating circumstances, to issue or update current written policies and procedures for review and approval in accordance with paragraph (c) of this section and consistent with the requirements of this part." 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause The County's management was not aware of the compliance requirement relating to the written procurement policy. Effect The failure to establish a written policy for Federal Procurement placed the County in noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Noncompliance with the grant agreement and the compliance requirement could result in the repayment of federal funds. INDIANA STATE BOARD OF ACCOUNTS 16 RUSH COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the County's management establish written policies and procedures for the procurement of engineering and design services. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that part of this report.
2024-001 – Fiscal Policies and Procedures Not Fully Aligned with Uniform Guidance Federal Program: Temporary Assistance for Needy Families, Family Violence Prevention Services Act, ARP Supplemental and ARP Covid-19 Federal Assistance Listing Number: 93.558 and 93.671 Pass-Through Agency: Texas Health and Human Services Commission Pass-Through Grantor Number: HHS000380000040 Criteria: Non-federal entities are required under 2 CFR §200.303 to establish and maintain effective internal controls over federal awards that provide reasonable assurance of compliance with federal statutes, regulations, and terms and conditions of the award. Adequate written policies and procedures are a critical component of an effective internal control system. Condition: During our review of the Center’s fiscal policies and procedures, we noted that several key elements required for compliance with 2 CFR Part 200 were either missing or lacked sufficient detail. Specifically, the following areas were underdeveloped: Conflict of interest policies were not clearly defined or aligned with 2 CFR § 200.112. Procedures for determining allowable costs under 2 CFR §200.403–§200.405 were not well documented. Subrecipient monitoring procedures required by 2 CFR §200.331 were not adequately addressed. Record retention and access policies under 2 CFR §200.333–§200.338 were not clearly outlined. While some general policies were in place, they do not currently meet the level of specificity and comprehensiveness required under the Uniform Guidance. Cause: The Center is in the process of updating its financial policies and procedures to comply with Uniform Guidance requirements. A consultant has been engaged to assist with this process, and updates are expected to be finalized and approved by the Board of Directors in August 2025. Effect: The lack of complete and detailed policies increases the risk of noncompliance with federal requirements, especially in areas such as cost allowability, subrecipient oversight, and recordkeeping. It also creates challenges in ensuring consistent and compliant financial practices across the Center. Questioned Costs: $0 – No noncompliant expenditures were identified; however, the absence of sufficient policies represents a control deficiency. Recommendation: We recommend for the Center to prioritize the completion and formal adoption of revised fiscal policies and procedures, ensuring they fully align with the requirements of 2 CFR Part 200. These should include detailed written policies on conflict of interest, allowable costs, subrecipient monitoring, and record retention. Finalizing and implementing these policies ahead of the new fiscal year, as planned, will strengthen internal controls and help ensure compliance moving forward. Management’s Views and Corrective Action Plan: Management agrees with the finding. The Center is currently in the process of updating its fiscal policies and procedures to align with the requirements of 2 CFR Part 200. The Finance Committee is leading this effort and is reviewing each policy area identified, including conflict of interest, allowable costs, subrecipient monitoring, and record retention. Updated policies and procedures will be finalized and presented for Board approval by August 30, 2025. Once approved, the Center will ensure implementation across all departments and provide internal guidance to promote consistent application. Anticipated Completion Date: August 30, 2025 Responsible Party: Finance Committee, with support from Executive Director, Nichole Henry.
2024-001 – Fiscal Policies and Procedures Not Fully Aligned with Uniform Guidance Federal Program: Temporary Assistance for Needy Families, Family Violence Prevention Services Act, ARP Supplemental and ARP Covid-19 Federal Assistance Listing Number: 93.558 and 93.671 Pass-Through Agency: Texas Health and Human Services Commission Pass-Through Grantor Number: HHS000380000040 Criteria: Non-federal entities are required under 2 CFR §200.303 to establish and maintain effective internal controls over federal awards that provide reasonable assurance of compliance with federal statutes, regulations, and terms and conditions of the award. Adequate written policies and procedures are a critical component of an effective internal control system. Condition: During our review of the Center’s fiscal policies and procedures, we noted that several key elements required for compliance with 2 CFR Part 200 were either missing or lacked sufficient detail. Specifically, the following areas were underdeveloped: Conflict of interest policies were not clearly defined or aligned with 2 CFR § 200.112. Procedures for determining allowable costs under 2 CFR §200.403–§200.405 were not well documented. Subrecipient monitoring procedures required by 2 CFR §200.331 were not adequately addressed. Record retention and access policies under 2 CFR §200.333–§200.338 were not clearly outlined. While some general policies were in place, they do not currently meet the level of specificity and comprehensiveness required under the Uniform Guidance. Cause: The Center is in the process of updating its financial policies and procedures to comply with Uniform Guidance requirements. A consultant has been engaged to assist with this process, and updates are expected to be finalized and approved by the Board of Directors in August 2025. Effect: The lack of complete and detailed policies increases the risk of noncompliance with federal requirements, especially in areas such as cost allowability, subrecipient oversight, and recordkeeping. It also creates challenges in ensuring consistent and compliant financial practices across the Center. Questioned Costs: $0 – No noncompliant expenditures were identified; however, the absence of sufficient policies represents a control deficiency. Recommendation: We recommend for the Center to prioritize the completion and formal adoption of revised fiscal policies and procedures, ensuring they fully align with the requirements of 2 CFR Part 200. These should include detailed written policies on conflict of interest, allowable costs, subrecipient monitoring, and record retention. Finalizing and implementing these policies ahead of the new fiscal year, as planned, will strengthen internal controls and help ensure compliance moving forward. Management’s Views and Corrective Action Plan: Management agrees with the finding. The Center is currently in the process of updating its fiscal policies and procedures to align with the requirements of 2 CFR Part 200. The Finance Committee is leading this effort and is reviewing each policy area identified, including conflict of interest, allowable costs, subrecipient monitoring, and record retention. Updated policies and procedures will be finalized and presented for Board approval by August 30, 2025. Once approved, the Center will ensure implementation across all departments and provide internal guidance to promote consistent application. Anticipated Completion Date: August 30, 2025 Responsible Party: Finance Committee, with support from Executive Director, Nichole Henry.
2024-001 – Fiscal Policies and Procedures Not Fully Aligned with Uniform Guidance Federal Program: Temporary Assistance for Needy Families, Family Violence Prevention Services Act, ARP Supplemental and ARP Covid-19 Federal Assistance Listing Number: 93.558 and 93.671 Pass-Through Agency: Texas Health and Human Services Commission Pass-Through Grantor Number: HHS000380000040 Criteria: Non-federal entities are required under 2 CFR §200.303 to establish and maintain effective internal controls over federal awards that provide reasonable assurance of compliance with federal statutes, regulations, and terms and conditions of the award. Adequate written policies and procedures are a critical component of an effective internal control system. Condition: During our review of the Center’s fiscal policies and procedures, we noted that several key elements required for compliance with 2 CFR Part 200 were either missing or lacked sufficient detail. Specifically, the following areas were underdeveloped: Conflict of interest policies were not clearly defined or aligned with 2 CFR § 200.112. Procedures for determining allowable costs under 2 CFR §200.403–§200.405 were not well documented. Subrecipient monitoring procedures required by 2 CFR §200.331 were not adequately addressed. Record retention and access policies under 2 CFR §200.333–§200.338 were not clearly outlined. While some general policies were in place, they do not currently meet the level of specificity and comprehensiveness required under the Uniform Guidance. Cause: The Center is in the process of updating its financial policies and procedures to comply with Uniform Guidance requirements. A consultant has been engaged to assist with this process, and updates are expected to be finalized and approved by the Board of Directors in August 2025. Effect: The lack of complete and detailed policies increases the risk of noncompliance with federal requirements, especially in areas such as cost allowability, subrecipient oversight, and recordkeeping. It also creates challenges in ensuring consistent and compliant financial practices across the Center. Questioned Costs: $0 – No noncompliant expenditures were identified; however, the absence of sufficient policies represents a control deficiency. Recommendation: We recommend for the Center to prioritize the completion and formal adoption of revised fiscal policies and procedures, ensuring they fully align with the requirements of 2 CFR Part 200. These should include detailed written policies on conflict of interest, allowable costs, subrecipient monitoring, and record retention. Finalizing and implementing these policies ahead of the new fiscal year, as planned, will strengthen internal controls and help ensure compliance moving forward. Management’s Views and Corrective Action Plan: Management agrees with the finding. The Center is currently in the process of updating its fiscal policies and procedures to align with the requirements of 2 CFR Part 200. The Finance Committee is leading this effort and is reviewing each policy area identified, including conflict of interest, allowable costs, subrecipient monitoring, and record retention. Updated policies and procedures will be finalized and presented for Board approval by August 30, 2025. Once approved, the Center will ensure implementation across all departments and provide internal guidance to promote consistent application. Anticipated Completion Date: August 30, 2025 Responsible Party: Finance Committee, with support from Executive Director, Nichole Henry.
2024-001 – Fiscal Policies and Procedures Not Fully Aligned with Uniform Guidance Federal Program: Temporary Assistance for Needy Families, Family Violence Prevention Services Act, ARP Supplemental and ARP Covid-19 Federal Assistance Listing Number: 93.558 and 93.671 Pass-Through Agency: Texas Health and Human Services Commission Pass-Through Grantor Number: HHS000380000040 Criteria: Non-federal entities are required under 2 CFR §200.303 to establish and maintain effective internal controls over federal awards that provide reasonable assurance of compliance with federal statutes, regulations, and terms and conditions of the award. Adequate written policies and procedures are a critical component of an effective internal control system. Condition: During our review of the Center’s fiscal policies and procedures, we noted that several key elements required for compliance with 2 CFR Part 200 were either missing or lacked sufficient detail. Specifically, the following areas were underdeveloped: Conflict of interest policies were not clearly defined or aligned with 2 CFR § 200.112. Procedures for determining allowable costs under 2 CFR §200.403–§200.405 were not well documented. Subrecipient monitoring procedures required by 2 CFR §200.331 were not adequately addressed. Record retention and access policies under 2 CFR §200.333–§200.338 were not clearly outlined. While some general policies were in place, they do not currently meet the level of specificity and comprehensiveness required under the Uniform Guidance. Cause: The Center is in the process of updating its financial policies and procedures to comply with Uniform Guidance requirements. A consultant has been engaged to assist with this process, and updates are expected to be finalized and approved by the Board of Directors in August 2025. Effect: The lack of complete and detailed policies increases the risk of noncompliance with federal requirements, especially in areas such as cost allowability, subrecipient oversight, and recordkeeping. It also creates challenges in ensuring consistent and compliant financial practices across the Center. Questioned Costs: $0 – No noncompliant expenditures were identified; however, the absence of sufficient policies represents a control deficiency. Recommendation: We recommend for the Center to prioritize the completion and formal adoption of revised fiscal policies and procedures, ensuring they fully align with the requirements of 2 CFR Part 200. These should include detailed written policies on conflict of interest, allowable costs, subrecipient monitoring, and record retention. Finalizing and implementing these policies ahead of the new fiscal year, as planned, will strengthen internal controls and help ensure compliance moving forward. Management’s Views and Corrective Action Plan: Management agrees with the finding. The Center is currently in the process of updating its fiscal policies and procedures to align with the requirements of 2 CFR Part 200. The Finance Committee is leading this effort and is reviewing each policy area identified, including conflict of interest, allowable costs, subrecipient monitoring, and record retention. Updated policies and procedures will be finalized and presented for Board approval by August 30, 2025. Once approved, the Center will ensure implementation across all departments and provide internal guidance to promote consistent application. Anticipated Completion Date: August 30, 2025 Responsible Party: Finance Committee, with support from Executive Director, Nichole Henry.
FINDING 2024-001 Subject: Highway Planning and Construction - Procurement Federal Agency: Department of Transportation Federal Program: Highway Planning and Construction Assistance Listings Number: 20.205 Federal Award Numbers and Years (or Other Identifying Numbers): DES. Nos. 1600968, 1702753, 1802927, 1802929, 1902066, 2301613 Pass-Through Entity: Indiana Department of Transportation Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context Recipients may use award funds to procure engineering and design-related services from consultants necessary to implement one or more eligible purposes outlined for the Highway Planning and Construction award funds. Subrecipients may adopt written policies and procedures prescribed by the awarding state DOT or prepare their own written policies and procedures approved by the Indiana Department of Transportation. The County did not have documented procurement procedures or policies used to procure engineering and design services. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 23 CFR 175 states in part: ". . . (b) Subrecipient responsibilities. Subrecipients shall develop and sustain organizational capacity and provide the resources necessary for the procurement, management, and administration of engineering and design related consultant services, reimbursed in whole or in part with FAHP funding as specified in 23 U.S.C. 106(g)(4)(A). Responsibilities shall include the following: (1) Adopting written policies and procedures prescribed by the awarding STA or other recipient for the procurement, management, and administration of engineering and design related consultant services in accordance with applicable Federal and State laws and regulations; or when not prescribed, shall include: (i) Preparing and maintaining its own written policies and procedures in accordance with paragraph (c) of this section; or (ii) Submitting documentation associated with each procurement and subsequent contract to the awarding STA or other grantee for review to assess compliance with applicable Federal and State laws, regulations, and the requirements of this part; (2) Procuring, managing, and administering engineering and design related consultant services in accordance with applicable Federal and State laws, regulations, and approved policies and procedures, as specified in 23 CFR 1.9(a). INDIANA STATE BOARD OF ACCOUNTS 14 RUSH COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (c) Written policies and procedures. The contracting agency shall prepare and maintain written policies and procedures for the procurement, management, and administration of engineering and design related consultant services. The FHWA shall approve the written policies and procedures, including all revisions to such policies and procedures, of the STA or recipient to assess compliance with applicable requirements. The STA or other recipient shall approve the written policies and procedures, including all revisions to such policies and procedures, of a subrecipient to assess compliance with applicable requirements. These policies and procedures shall address, as appropriate for each method of procurement a contracting agency proposes to use, the following items to ensure compliance with Federal and State laws, regulations, and the requirements of this part: (1) Preparing a scope of work and evaluation factors for the ranking/selection of a consultant; (2) Soliciting interests, qualifications, or proposals from prospective consultants; (3) Preventing, identifying, and mitigating conflicts of interest for employees of both the contracting agency and consultants and promptly disclosing in writing any potential conflict to the STA and FHWA, as specified in 2 CFR 200.112 and 23 CFR 1.33, and the requirements of this part. (4) Verifying suspension and debarment actions and eligibility of consultants, as specified in 2 CFR part 1200 and 2 CFR part 180; (5) Evaluating interests, qualifications, or proposals and the ranking/selection of a consultant; (6) Determining, based upon State procedures and the size and complexity of a project, the need for additional discussions following RFP submission and evaluation; (7) Preparing an independent agency estimate for use in negotiation with the selected consultant; (8) Selecting appropriate contract type, payment method, and terms and incorporating required contract provisions, assurances, and certifications in accordance with § 172.9; (9) Negotiating a contract with the selected consultant including instructions for proper disposal of concealed cost proposals of unsuccessful bidders; (10) Establishing elements of contract costs, accepting indirect cost rate(s) for application to contracts, and assuring consultant compliance with the Federal cost principles in accordance with § 172.11; (11) Ensuring consultant costs billed are allowable in accordance with the Federal cost principles and consistent with the contract terms as well as the acceptability and progress of the consultant's work; (12) Monitoring the consultant's work and compliance with the terms, conditions, and specifications of the contract; (13) Preparing a consultant's performance evaluation when services are completed and using such performance data in future evaluation and ranking of consultant to provide similar services; INDIANA STATE BOARD OF ACCOUNTS 15 RUSH COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (14) Closing-out a contract; (15) Retaining supporting programmatic and contract records, as specified in 2 CFR 200.333 and the requirements of this part; (16) Determining the extent to which the consultant, which is responsible for the professional quality, technical accuracy, and coordination of services, may be reasonably liable for costs resulting from errors and omissions in the work furnished under its contract; (17) Assessing administrative, contractual, or legal remedies in instances where consultants violate or breach contract terms and conditions, and providing for such sanctions and penalties as may be appropriate; and (18) Resolving disputes in the procurement, management, and administration of engineering and design related consultant services. (d) A contracting agency may formally adopt, by statute or within approved written policies and procedures as specified in paragraph (c) of this section, any direct Federal Government or other contracting regulation, standard, or procedure provided its application does not conflict with the provisions of 23 U.S.C. 112, the requirements of this part, and other laws and regulations applicable to the FAHP. (e) Notwithstanding paragraph (d) of this section, a contracting agency shall have a reasonable period of time, not to exceed 12 months from the effective date of this rule unless an extension is granted for unique or extenuating circumstances, to issue or update current written policies and procedures for review and approval in accordance with paragraph (c) of this section and consistent with the requirements of this part." 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause The County's management was not aware of the compliance requirement relating to the written procurement policy. Effect The failure to establish a written policy for Federal Procurement placed the County in noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Noncompliance with the grant agreement and the compliance requirement could result in the repayment of federal funds. INDIANA STATE BOARD OF ACCOUNTS 16 RUSH COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the County's management establish written policies and procedures for the procurement of engineering and design services. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that part of this report.
2024-001 – Fiscal Policies and Procedures Not Fully Aligned with Uniform Guidance Federal Program: Temporary Assistance for Needy Families, Family Violence Prevention Services Act, ARP Supplemental and ARP Covid-19 Federal Assistance Listing Number: 93.558 and 93.671 Pass-Through Agency: Texas Health and Human Services Commission Pass-Through Grantor Number: HHS000380000040 Criteria: Non-federal entities are required under 2 CFR §200.303 to establish and maintain effective internal controls over federal awards that provide reasonable assurance of compliance with federal statutes, regulations, and terms and conditions of the award. Adequate written policies and procedures are a critical component of an effective internal control system. Condition: During our review of the Center’s fiscal policies and procedures, we noted that several key elements required for compliance with 2 CFR Part 200 were either missing or lacked sufficient detail. Specifically, the following areas were underdeveloped: Conflict of interest policies were not clearly defined or aligned with 2 CFR § 200.112. Procedures for determining allowable costs under 2 CFR §200.403–§200.405 were not well documented. Subrecipient monitoring procedures required by 2 CFR §200.331 were not adequately addressed. Record retention and access policies under 2 CFR §200.333–§200.338 were not clearly outlined. While some general policies were in place, they do not currently meet the level of specificity and comprehensiveness required under the Uniform Guidance. Cause: The Center is in the process of updating its financial policies and procedures to comply with Uniform Guidance requirements. A consultant has been engaged to assist with this process, and updates are expected to be finalized and approved by the Board of Directors in August 2025. Effect: The lack of complete and detailed policies increases the risk of noncompliance with federal requirements, especially in areas such as cost allowability, subrecipient oversight, and recordkeeping. It also creates challenges in ensuring consistent and compliant financial practices across the Center. Questioned Costs: $0 – No noncompliant expenditures were identified; however, the absence of sufficient policies represents a control deficiency. Recommendation: We recommend for the Center to prioritize the completion and formal adoption of revised fiscal policies and procedures, ensuring they fully align with the requirements of 2 CFR Part 200. These should include detailed written policies on conflict of interest, allowable costs, subrecipient monitoring, and record retention. Finalizing and implementing these policies ahead of the new fiscal year, as planned, will strengthen internal controls and help ensure compliance moving forward. Management’s Views and Corrective Action Plan: Management agrees with the finding. The Center is currently in the process of updating its fiscal policies and procedures to align with the requirements of 2 CFR Part 200. The Finance Committee is leading this effort and is reviewing each policy area identified, including conflict of interest, allowable costs, subrecipient monitoring, and record retention. Updated policies and procedures will be finalized and presented for Board approval by August 30, 2025. Once approved, the Center will ensure implementation across all departments and provide internal guidance to promote consistent application. Anticipated Completion Date: August 30, 2025 Responsible Party: Finance Committee, with support from Executive Director, Nichole Henry.
2024-001 – Fiscal Policies and Procedures Not Fully Aligned with Uniform Guidance Federal Program: Temporary Assistance for Needy Families, Family Violence Prevention Services Act, ARP Supplemental and ARP Covid-19 Federal Assistance Listing Number: 93.558 and 93.671 Pass-Through Agency: Texas Health and Human Services Commission Pass-Through Grantor Number: HHS000380000040 Criteria: Non-federal entities are required under 2 CFR §200.303 to establish and maintain effective internal controls over federal awards that provide reasonable assurance of compliance with federal statutes, regulations, and terms and conditions of the award. Adequate written policies and procedures are a critical component of an effective internal control system. Condition: During our review of the Center’s fiscal policies and procedures, we noted that several key elements required for compliance with 2 CFR Part 200 were either missing or lacked sufficient detail. Specifically, the following areas were underdeveloped: Conflict of interest policies were not clearly defined or aligned with 2 CFR § 200.112. Procedures for determining allowable costs under 2 CFR §200.403–§200.405 were not well documented. Subrecipient monitoring procedures required by 2 CFR §200.331 were not adequately addressed. Record retention and access policies under 2 CFR §200.333–§200.338 were not clearly outlined. While some general policies were in place, they do not currently meet the level of specificity and comprehensiveness required under the Uniform Guidance. Cause: The Center is in the process of updating its financial policies and procedures to comply with Uniform Guidance requirements. A consultant has been engaged to assist with this process, and updates are expected to be finalized and approved by the Board of Directors in August 2025. Effect: The lack of complete and detailed policies increases the risk of noncompliance with federal requirements, especially in areas such as cost allowability, subrecipient oversight, and recordkeeping. It also creates challenges in ensuring consistent and compliant financial practices across the Center. Questioned Costs: $0 – No noncompliant expenditures were identified; however, the absence of sufficient policies represents a control deficiency. Recommendation: We recommend for the Center to prioritize the completion and formal adoption of revised fiscal policies and procedures, ensuring they fully align with the requirements of 2 CFR Part 200. These should include detailed written policies on conflict of interest, allowable costs, subrecipient monitoring, and record retention. Finalizing and implementing these policies ahead of the new fiscal year, as planned, will strengthen internal controls and help ensure compliance moving forward. Management’s Views and Corrective Action Plan: Management agrees with the finding. The Center is currently in the process of updating its fiscal policies and procedures to align with the requirements of 2 CFR Part 200. The Finance Committee is leading this effort and is reviewing each policy area identified, including conflict of interest, allowable costs, subrecipient monitoring, and record retention. Updated policies and procedures will be finalized and presented for Board approval by August 30, 2025. Once approved, the Center will ensure implementation across all departments and provide internal guidance to promote consistent application. Anticipated Completion Date: August 30, 2025 Responsible Party: Finance Committee, with support from Executive Director, Nichole Henry.
2024-001 – Fiscal Policies and Procedures Not Fully Aligned with Uniform Guidance Federal Program: Temporary Assistance for Needy Families, Family Violence Prevention Services Act, ARP Supplemental and ARP Covid-19 Federal Assistance Listing Number: 93.558 and 93.671 Pass-Through Agency: Texas Health and Human Services Commission Pass-Through Grantor Number: HHS000380000040 Criteria: Non-federal entities are required under 2 CFR §200.303 to establish and maintain effective internal controls over federal awards that provide reasonable assurance of compliance with federal statutes, regulations, and terms and conditions of the award. Adequate written policies and procedures are a critical component of an effective internal control system. Condition: During our review of the Center’s fiscal policies and procedures, we noted that several key elements required for compliance with 2 CFR Part 200 were either missing or lacked sufficient detail. Specifically, the following areas were underdeveloped: Conflict of interest policies were not clearly defined or aligned with 2 CFR § 200.112. Procedures for determining allowable costs under 2 CFR §200.403–§200.405 were not well documented. Subrecipient monitoring procedures required by 2 CFR §200.331 were not adequately addressed. Record retention and access policies under 2 CFR §200.333–§200.338 were not clearly outlined. While some general policies were in place, they do not currently meet the level of specificity and comprehensiveness required under the Uniform Guidance. Cause: The Center is in the process of updating its financial policies and procedures to comply with Uniform Guidance requirements. A consultant has been engaged to assist with this process, and updates are expected to be finalized and approved by the Board of Directors in August 2025. Effect: The lack of complete and detailed policies increases the risk of noncompliance with federal requirements, especially in areas such as cost allowability, subrecipient oversight, and recordkeeping. It also creates challenges in ensuring consistent and compliant financial practices across the Center. Questioned Costs: $0 – No noncompliant expenditures were identified; however, the absence of sufficient policies represents a control deficiency. Recommendation: We recommend for the Center to prioritize the completion and formal adoption of revised fiscal policies and procedures, ensuring they fully align with the requirements of 2 CFR Part 200. These should include detailed written policies on conflict of interest, allowable costs, subrecipient monitoring, and record retention. Finalizing and implementing these policies ahead of the new fiscal year, as planned, will strengthen internal controls and help ensure compliance moving forward. Management’s Views and Corrective Action Plan: Management agrees with the finding. The Center is currently in the process of updating its fiscal policies and procedures to align with the requirements of 2 CFR Part 200. The Finance Committee is leading this effort and is reviewing each policy area identified, including conflict of interest, allowable costs, subrecipient monitoring, and record retention. Updated policies and procedures will be finalized and presented for Board approval by August 30, 2025. Once approved, the Center will ensure implementation across all departments and provide internal guidance to promote consistent application. Anticipated Completion Date: August 30, 2025 Responsible Party: Finance Committee, with support from Executive Director, Nichole Henry.
2024-001 – Fiscal Policies and Procedures Not Fully Aligned with Uniform Guidance Federal Program: Temporary Assistance for Needy Families, Family Violence Prevention Services Act, ARP Supplemental and ARP Covid-19 Federal Assistance Listing Number: 93.558 and 93.671 Pass-Through Agency: Texas Health and Human Services Commission Pass-Through Grantor Number: HHS000380000040 Criteria: Non-federal entities are required under 2 CFR §200.303 to establish and maintain effective internal controls over federal awards that provide reasonable assurance of compliance with federal statutes, regulations, and terms and conditions of the award. Adequate written policies and procedures are a critical component of an effective internal control system. Condition: During our review of the Center’s fiscal policies and procedures, we noted that several key elements required for compliance with 2 CFR Part 200 were either missing or lacked sufficient detail. Specifically, the following areas were underdeveloped: Conflict of interest policies were not clearly defined or aligned with 2 CFR § 200.112. Procedures for determining allowable costs under 2 CFR §200.403–§200.405 were not well documented. Subrecipient monitoring procedures required by 2 CFR §200.331 were not adequately addressed. Record retention and access policies under 2 CFR §200.333–§200.338 were not clearly outlined. While some general policies were in place, they do not currently meet the level of specificity and comprehensiveness required under the Uniform Guidance. Cause: The Center is in the process of updating its financial policies and procedures to comply with Uniform Guidance requirements. A consultant has been engaged to assist with this process, and updates are expected to be finalized and approved by the Board of Directors in August 2025. Effect: The lack of complete and detailed policies increases the risk of noncompliance with federal requirements, especially in areas such as cost allowability, subrecipient oversight, and recordkeeping. It also creates challenges in ensuring consistent and compliant financial practices across the Center. Questioned Costs: $0 – No noncompliant expenditures were identified; however, the absence of sufficient policies represents a control deficiency. Recommendation: We recommend for the Center to prioritize the completion and formal adoption of revised fiscal policies and procedures, ensuring they fully align with the requirements of 2 CFR Part 200. These should include detailed written policies on conflict of interest, allowable costs, subrecipient monitoring, and record retention. Finalizing and implementing these policies ahead of the new fiscal year, as planned, will strengthen internal controls and help ensure compliance moving forward. Management’s Views and Corrective Action Plan: Management agrees with the finding. The Center is currently in the process of updating its fiscal policies and procedures to align with the requirements of 2 CFR Part 200. The Finance Committee is leading this effort and is reviewing each policy area identified, including conflict of interest, allowable costs, subrecipient monitoring, and record retention. Updated policies and procedures will be finalized and presented for Board approval by August 30, 2025. Once approved, the Center will ensure implementation across all departments and provide internal guidance to promote consistent application. Anticipated Completion Date: August 30, 2025 Responsible Party: Finance Committee, with support from Executive Director, Nichole Henry.
Finding 2025-001: Cash Management (Material Weakness) Federal Program: Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White Part C). [93.918] Federal Agency: U.S. Department of Health and Human Services (HHS) Criteria: Effective internal controls require an entity to have a financial management system that provides accurate, current, and complete disclosure of the financial results of a federally assisted project (2 CFR § 200.302). Drawdown requests must be based on actual incurred expenditures and be properly reviewed for accuracy before submission to minimize the time between draw and disbursement (2 CFR § 200.305). Additionally, the entity must maintain records that adequately identify the source and application of funds for all federally assisted activities (2 CFR § 200.333). Condition: During our audit of the financial management system and cash management practices for the Ryan White Federal Program, we identified the following deficiencies: Transposed Drawdown Amount: A drawdown request submitted to the PMS system for the Ryan White Program had the requested amount transposed with the amount of another federal program. This resulted in an over-request of a material amount on the Ryan White Program. Duplicate Invoice Reimbursement: An invoice was requested and received for reimbursement on a prior drawdown and was subsequently included again in a draw after year-end, resulting in a duplicate reimbursement. Incomplete Expenditure Tracking: The entity did not have a complete system for tracking all expenditures eligible for reimbursement. The drawdown process was limited to cash disbursement and payroll transactions and excluded expenditures incurred and recorded by journal entries. This resulted in the entity having unreimbursed expenditures that could have offset the over-requests noted above. Questioned Costs: $252,567 The questioned costs consist of the material amount over-requested in the transposed drawdown and the duplicate reimbursement of the previously paid invoice. A detailed breakdown is as follows: Over-requested amount due to transposed data: $150,516 Duplicate reimbursement for invoice submitted twice: $102,051 Cause: The organization's internal controls over the cash management and drawdown request process were inadequate. Specifically, there was a lack of a formal review and approval process to verify the accuracy and completeness of drawdown requests before they were submitted. Effect: The deficiencies in internal control led to material noncompliance with federal regulations related to financial management and cash management. This resulted in the entity holding federal funds in excess of immediate needs, which is a violation of the terms and conditions of the federal award. The inadequate financial management system also prevented the entity from accurately tracking and requesting all eligible expenditures, which could have helped offset the over-draws. Context: This is a systemic finding. Repeat Finding: No. This is the first time this specific finding has been identified. Recommendation: The entity should implement robust internal controls to ensure all drawdown requests are reviewed and approved by a second person with authority. A reconciliation of expenditures to the general ledger should be performed before each drawdown to ensure all eligible costs are included and that no duplicate requests are made. The entity’s cash management policies and procedures should be updated to address these deficiencies and ensure compliance with federal requirements. Management Response: The organization acknowledges and we are committed to remediation. To correct the deficiency, we are implementing a plan focused on establishing a review and approval process for all drawdown requests and revising our policies to ensure that all eligible incurred expenditures are properly captured and reconciled, thereby assuring strict compliance with federal cash management regulations and preventing federal funds from exceeding our immediate needs.
Finding #2024-002 Lack of Subrecipient Monitoring – Rural eConnectivity Pilot Program (ALN 10.752) Federal Agency: U.S. Department of Agriculture Assistance Listing Number (ALN): 10.752 – Rural eConnectivity Pilot Program (Reconnect) Award Year: 2024 Compliance Requirement: Subrecipient Monitoring Criteria: In accordance with 2 CFR §200.331 through §200.333, pass-through entities must monitor the activities of subrecipients to ensure that federal awards are used for authorized purposes and in compliance with laws, regulations, and the provisions of contracts or grant agreements. Required monitoring activities include reviewing financial and programmatic reports, following up on deficiencies, and ensuring corrective actions are taken. Condition: The Town passed through approximately $1,650,000 in Rural eConnectivity (ReConnect) funds to a local electric Co-op for broadband infrastructure installation. However, the Town did not perform subrecipient monitoring by identifying applicable requirements for the award during or after the disbursement of these funds. The requirements imposed by the Town to the Co-op so the federal award was in accordance with federal statutes, regulations, and terms and conditions as well as any additional requirements in order for the Town to meet its own responsibilities for the federal award were not clearly communicated or imposed. Cause: Town officials stated that they believed subrecipient monitoring was not necessary because the funds had already been expended and the project was completed. Additionally, there was limited communication between the Town and the federal awarding agency, which contributed to a misunderstanding of the Town’s responsibilities as a pass-through entity. Effect: The lack of subrecipient monitoring represents noncompliance with federal requirements and creates a risk that funds may not have been used for their intended purpose. Without adequate oversight, the Town cannot demonstrate that the subrecipient complied with the terms and conditions of the federal award. Questioned Costs: None. Recommendation: We recommend that the Town establish and implement a formal subrecipient monitoring process for all federal funds passed through to other entities. This should include risk assessments, written agreements with compliance terms, ongoing monitoring (e.g., review of performance and financial reports), and follow-up procedures. The Town should also seek guidance from the awarding agency if responsibilities are unclear. Views of Responsible Officials: The Town concurs that applicable requirements for the award were not identified for the subrecipient, however the Town did monitor activities of the subrecipient. The Town monitored activities to ensure funds were used for allowable activities.
Finding Number: 2024-030 Prior Year Finding Number: 2023-035 Compliance Requirement: Reporting Program: U.S. Department of Health and Human Services Opioid STR ALN: 93.788 Award #: Various Award Year: 09/30/2020 – 09/29/2024 Government Department/Agency: Department of Behavioral Health (DBH) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Federal Financial Report (FFR) Controls over Reporting Compliance: 2 CFR 200.333 requires that financial records, supporting documents, statistical records, and all other non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the federal awarding agency or pass-through entity in the case of a subrecipient. Performance Progress Report (PPR) Underlying Data: The audit objective for the Reporting compliance requirement stated in the 2 CFR Part 200, appendix XI Compliance Supplement is as follows: Determine whether required reports for Federal awards include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. Schedule of Expenditures of Federal Awards (SEFA) Reporting Compliance: Requirements, Cost Principles, and Audit Requirements, section 200.510(b) states the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. Condition – During our testing of the reporting compliance requirement, we noted the following: • FFR Controls over Reporting Compliance: DBH’s control over compliance for financial reporting is as follows: “All reports are reviewed by the Accounting Officer or Agency Fiscal Officer prior to submission to the Federal government. DBH Program and Fiscal Services staff review programmatic and financial reports.” We noted DBH did not timely review and approve the annual Financial Reporting Report (FFR or SF-425) prior to submission to the Federal government. Total population is one (1) report and sample selected is one (1). • PPR Reporting Compliance: We noted DBH did not have documentation for the information, as well as the source of the information, it used in the Opioid STR’s Performance Progress Report. Information as reported in the reports was unsupported as management did not retain the underlying data. Total population is two (2) reports and sample selected is one (1). • SEFA Reporting Compliance: During our testing for the SEFA, we noted that DBH incorrectly reported the value of subrecipient expenditures included within the subrecipient expenditure column. For the year ended September 30, 2024, DBH incurred $12.0 million in subrecipient expenditures for this program and incorrectly reported that there were no subrecipient expenditures on the initial SEFA. While the subrecipient expenditures amount was not accurate, the total expenditures amount was accurately reported. The error in the subrecipient expenditures amount was subsequently identified and corrected as a result of the audit process. Questioned Costs – None. Context – This is a condition identified per review of DBH’s compliance with specified reporting requirements using a statistically valid sample. Effect – Without proper internal controls and policies and procedures in place to ensure that correct amounts were reported and were properly reviewed as it relates to the Opioid STR program: • FFR Controls over Reporting Compliance: There is an increased risk of errors occurring and being undetected, or errors being present in reports if no review and approval occurred. • PPR Reporting Compliance: DBH cannot be assured that it reported complete and accurate information to enable the Substance Abuse and Mental Health Services Administration (SAMHSA), an operating division of the Department of Health and Human Services (HHS), to assess the outcomes of the State’s use of Opioid program funding. • SEFA Reporting Compliance: The effect of the condition is that the SEFA was not accurately prepared. Cause – Management did not have proper internal controls and policies and procedures in place to ensure that the amounts on the FFR and SEFA were properly reported, and the reports were properly reviewed and approved. Recommendation – We recommend the following: • FFR Controls over Reporting Compliance: We recommend DBH strengthen its internal control to ensure timely review and approval of the FFR before report submission. • PPR Reporting Compliance: We recommend DBH develop formal, written procedures to identify the sources of information necessary and steps needed to compile accurate and complete information for the Opioid program performance reports; and retain in a central location all documentation that it used to support information included in each performance report it submits to the federal government. • SEFA Reporting Compliance: We recommend DBH ensure that agency personnel receive proper training on subrecipient versus vendor determination; as well as review existing policies and procedures for preparing the Schedule of Expenditures of Federal Awards to ensure that it is complete and accurate. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – The DBH Office of the Chief Financial Officer (OCFO) concurs with this finding. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.
U.S. Department of Health and Human Services - 93.432 Center for Independent Living 2024-007 Missing Supporting Documentation for Federal Reimbursement Claims Criteria: Per 2 CFR §200.333 (now §200.334), financial records, supporting documents, statistical records, and all other records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report. Furthermore, 2 CFR §200.302(b)(3) requires recipients to maintain records that adequately identify the source and application of funds for federally funded activities. Condition: During our audit of the Centers for Independent Living funded by the U.S. Department of Health and Human Services, we noted that the League did not retain adequate supporting documentation for reimbursement claims submitted during the year. Specifically, for October - December 2023 reimbursement claims tested, the actual claim forms submitted to the funding agency were missing. Cause: The missing documentation appears to have resulted from an inadequate document retention process and a lack of oversight in ensuring that federal claim records were properly filed and stored. Effect: The absence of supporting documentation for submitted claims limits the League’s ability to demonstrate compliance with federal requirements and increases the risk of questioned costs. It also impairs transparency and accountability for federal funds. Questioned Costs: $118,023 for October – December 2023 claims. Recommendation: We recommend the League strengthen its grant management procedures by implementing a centralized tracking system for grant expenditures and claims. Staff responsible for managing grants should receive training on claiming procedures and grant deadlines, and a periodic review of unclaimed eligible expenditures should be performed to ensure timely reimbursement. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan on page 50.
Finding Number: 2024-030 Prior Year Finding Number: 2023-035 Compliance Requirement: Reporting Program: U.S. Department of Health and Human Services Opioid STR ALN: 93.788 Award #: Various Award Year: 09/30/2020 – 09/29/2024 Government Department/Agency: Department of Behavioral Health (DBH) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Federal Financial Report (FFR) Controls over Reporting Compliance: 2 CFR 200.333 requires that financial records, supporting documents, statistical records, and all other non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the federal awarding agency or pass-through entity in the case of a subrecipient. Performance Progress Report (PPR) Underlying Data: The audit objective for the Reporting compliance requirement stated in the 2 CFR Part 200, appendix XI Compliance Supplement is as follows: Determine whether required reports for Federal awards include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. Schedule of Expenditures of Federal Awards (SEFA) Reporting Compliance: Requirements, Cost Principles, and Audit Requirements, section 200.510(b) states the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. Condition – During our testing of the reporting compliance requirement, we noted the following: • FFR Controls over Reporting Compliance: DBH’s control over compliance for financial reporting is as follows: “All reports are reviewed by the Accounting Officer or Agency Fiscal Officer prior to submission to the Federal government. DBH Program and Fiscal Services staff review programmatic and financial reports.” We noted DBH did not timely review and approve the annual Financial Reporting Report (FFR or SF-425) prior to submission to the Federal government. Total population is one (1) report and sample selected is one (1). • PPR Reporting Compliance: We noted DBH did not have documentation for the information, as well as the source of the information, it used in the Opioid STR’s Performance Progress Report. Information as reported in the reports was unsupported as management did not retain the underlying data. Total population is two (2) reports and sample selected is one (1). • SEFA Reporting Compliance: During our testing for the SEFA, we noted that DBH incorrectly reported the value of subrecipient expenditures included within the subrecipient expenditure column. For the year ended September 30, 2024, DBH incurred $12.0 million in subrecipient expenditures for this program and incorrectly reported that there were no subrecipient expenditures on the initial SEFA. While the subrecipient expenditures amount was not accurate, the total expenditures amount was accurately reported. The error in the subrecipient expenditures amount was subsequently identified and corrected as a result of the audit process. Questioned Costs – None. Context – This is a condition identified per review of DBH’s compliance with specified reporting requirements using a statistically valid sample. Effect – Without proper internal controls and policies and procedures in place to ensure that correct amounts were reported and were properly reviewed as it relates to the Opioid STR program: • FFR Controls over Reporting Compliance: There is an increased risk of errors occurring and being undetected, or errors being present in reports if no review and approval occurred. • PPR Reporting Compliance: DBH cannot be assured that it reported complete and accurate information to enable the Substance Abuse and Mental Health Services Administration (SAMHSA), an operating division of the Department of Health and Human Services (HHS), to assess the outcomes of the State’s use of Opioid program funding. • SEFA Reporting Compliance: The effect of the condition is that the SEFA was not accurately prepared. Cause – Management did not have proper internal controls and policies and procedures in place to ensure that the amounts on the FFR and SEFA were properly reported, and the reports were properly reviewed and approved. Recommendation – We recommend the following: • FFR Controls over Reporting Compliance: We recommend DBH strengthen its internal control to ensure timely review and approval of the FFR before report submission. • PPR Reporting Compliance: We recommend DBH develop formal, written procedures to identify the sources of information necessary and steps needed to compile accurate and complete information for the Opioid program performance reports; and retain in a central location all documentation that it used to support information included in each performance report it submits to the federal government. • SEFA Reporting Compliance: We recommend DBH ensure that agency personnel receive proper training on subrecipient versus vendor determination; as well as review existing policies and procedures for preparing the Schedule of Expenditures of Federal Awards to ensure that it is complete and accurate. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – The DBH Office of the Chief Financial Officer (OCFO) concurs with this finding. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.
U.S. Department of Health and Human Services - 93.432 Center for Independent Living 2024-007 Missing Supporting Documentation for Federal Reimbursement Claims Criteria: Per 2 CFR §200.333 (now §200.334), financial records, supporting documents, statistical records, and all other records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report. Furthermore, 2 CFR §200.302(b)(3) requires recipients to maintain records that adequately identify the source and application of funds for federally funded activities. Condition: During our audit of the Centers for Independent Living funded by the U.S. Department of Health and Human Services, we noted that the League did not retain adequate supporting documentation for reimbursement claims submitted during the year. Specifically, for October - December 2023 reimbursement claims tested, the actual claim forms submitted to the funding agency were missing. Cause: The missing documentation appears to have resulted from an inadequate document retention process and a lack of oversight in ensuring that federal claim records were properly filed and stored. Effect: The absence of supporting documentation for submitted claims limits the League’s ability to demonstrate compliance with federal requirements and increases the risk of questioned costs. It also impairs transparency and accountability for federal funds. Questioned Costs: $118,023 for October – December 2023 claims. Recommendation: We recommend the League strengthen its grant management procedures by implementing a centralized tracking system for grant expenditures and claims. Staff responsible for managing grants should receive training on claiming procedures and grant deadlines, and a periodic review of unclaimed eligible expenditures should be performed to ensure timely reimbursement. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan on page 50.
Finding #2024-001 – Inability to Produce Supporting Report to Confirm the Accuracy of the Verification Report Sample Condition: During the fiscal year ended June 30, 2024, the District was unable to provide a report that supported the accuracy of the verification report sample. This lack of documentation prevented us from verifying that the sample was appropriately selected and representative of the population, as required under federal regulations. Effect: The inability to confirm the accuracy and validity of the verification report sample compromises the reliability of compliance testing results. This creates a risk of noncompliance with federal program requirements and potential misreporting. Cause: The District transitioned to new software during the fiscal year and relied on the software to produce the sample without verifying the accuracy of the population data. Staff lacked an understanding of how the software selected samples and did not independently validate the sampling process. Criteria: Per 2 CFR § 200.333 (Retention requirements for records), recipients of federal awards must maintain adequate documentation to support financial and compliance-related activities. Additionally, accurate and reliable sampling procedures are critical for compliance with federal program requirements. Questioned Costs: None Recommendation: We recommend that the District implement a record retention policy that requires all supporting documentation for verification reports and samples to be maintained and reviewed for accuracy. We recommend that the District provide training to staff responsible for federal program compliance, emphasizing the importance of verifying population data and sampling processes. Obtain training from the software provider to ensure staff understand how the software generates samples and verify its accuracy. Establish a process for periodic internal reviews to confirm that all required documentation is retained and readily available for audit purposes. Response: The District agrees with the finding. During the fiscal year 2024, the District will obtain training from the software provider to ensure reports are accurate and will no longer rely solely on the system without validation.
Finding #2024-001 – Inability to Produce Supporting Report to Confirm the Accuracy of the Verification Report Sample Condition: During the fiscal year ended June 30, 2024, the District was unable to provide a report that supported the accuracy of the verification report sample. This lack of documentation prevented us from verifying that the sample was appropriately selected and representative of the population, as required under federal regulations. Effect: The inability to confirm the accuracy and validity of the verification report sample compromises the reliability of compliance testing results. This creates a risk of noncompliance with federal program requirements and potential misreporting. Cause: The District transitioned to new software during the fiscal year and relied on the software to produce the sample without verifying the accuracy of the population data. Staff lacked an understanding of how the software selected samples and did not independently validate the sampling process. Criteria: Per 2 CFR § 200.333 (Retention requirements for records), recipients of federal awards must maintain adequate documentation to support financial and compliance-related activities. Additionally, accurate and reliable sampling procedures are critical for compliance with federal program requirements. Questioned Costs: None Recommendation: We recommend that the District implement a record retention policy that requires all supporting documentation for verification reports and samples to be maintained and reviewed for accuracy. We recommend that the District provide training to staff responsible for federal program compliance, emphasizing the importance of verifying population data and sampling processes. Obtain training from the software provider to ensure staff understand how the software generates samples and verify its accuracy. Establish a process for periodic internal reviews to confirm that all required documentation is retained and readily available for audit purposes. Response: The District agrees with the finding. During the fiscal year 2024, the District will obtain training from the software provider to ensure reports are accurate and will no longer rely solely on the system without validation.
Finding #2024-001 – Inability to Produce Supporting Report to Confirm the Accuracy of the Verification Report Sample Condition: During the fiscal year ended June 30, 2024, the District was unable to provide a report that supported the accuracy of the verification report sample. This lack of documentation prevented us from verifying that the sample was appropriately selected and representative of the population, as required under federal regulations. Effect: The inability to confirm the accuracy and validity of the verification report sample compromises the reliability of compliance testing results. This creates a risk of noncompliance with federal program requirements and potential misreporting. Cause: The District transitioned to new software during the fiscal year and relied on the software to produce the sample without verifying the accuracy of the population data. Staff lacked an understanding of how the software selected samples and did not independently validate the sampling process. Criteria: Per 2 CFR § 200.333 (Retention requirements for records), recipients of federal awards must maintain adequate documentation to support financial and compliance-related activities. Additionally, accurate and reliable sampling procedures are critical for compliance with federal program requirements. Questioned Costs: None Recommendation: We recommend that the District implement a record retention policy that requires all supporting documentation for verification reports and samples to be maintained and reviewed for accuracy. We recommend that the District provide training to staff responsible for federal program compliance, emphasizing the importance of verifying population data and sampling processes. Obtain training from the software provider to ensure staff understand how the software generates samples and verify its accuracy. Establish a process for periodic internal reviews to confirm that all required documentation is retained and readily available for audit purposes. Response: The District agrees with the finding. During the fiscal year 2024, the District will obtain training from the software provider to ensure reports are accurate and will no longer rely solely on the system without validation.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers: S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Annual Report Card, High School Graduation Rate Audit Findings: Significant Deficiency Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain information from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or deceased." 2 CFR 200.333 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient..." 2 CFR 200.334 (Revised Uniform Guidance) states in part: “Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Cause: Management had not developed nor implemented a system of internal control that would have ensured compliance with the grant agreement and the Special Tests and Provisions compliance requirement. Effect: The failure to establish an effective internal control system could enable noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Annual Report Card, High School Graduation Rate compliance requirement could result in loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. There was no formal documented review of mobility reports in Skyward during our audit period. Identification as a repeat finding: This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Recommendation: We recommended that the School Corporation's management establish an effective system of internal control to ensure compliance and comply with the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers: S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Annual Report Card, High School Graduation Rate Audit Findings: Significant Deficiency Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain information from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or deceased." 2 CFR 200.333 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient..." 2 CFR 200.334 (Revised Uniform Guidance) states in part: “Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Cause: Management had not developed nor implemented a system of internal control that would have ensured compliance with the grant agreement and the Special Tests and Provisions compliance requirement. Effect: The failure to establish an effective internal control system could enable noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Annual Report Card, High School Graduation Rate compliance requirement could result in loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. There was no formal documented review of mobility reports in Skyward during our audit period. Identification as a repeat finding: This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Recommendation: We recommended that the School Corporation's management establish an effective system of internal control to ensure compliance and comply with the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers: S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Annual Report Card, High School Graduation Rate Audit Findings: Significant Deficiency Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain information from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or deceased." 2 CFR 200.333 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient..." 2 CFR 200.334 (Revised Uniform Guidance) states in part: “Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Cause: Management had not developed nor implemented a system of internal control that would have ensured compliance with the grant agreement and the Special Tests and Provisions compliance requirement. Effect: The failure to establish an effective internal control system could enable noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Annual Report Card, High School Graduation Rate compliance requirement could result in loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. There was no formal documented review of mobility reports in Skyward during our audit period. Identification as a repeat finding: This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Recommendation: We recommended that the School Corporation's management establish an effective system of internal control to ensure compliance and comply with the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding Number: 2024-004 Agency: Department of Health & Human Services Federal Program: Immunization Cooperative Agreement ALN: 93.268 Grant Number: Various Compliance Requirement: Cash Management Category: Significant Deficiency in Internal Control over Compliance Criteria 2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. 2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition During our procedures, we found the following exceptions: a) In a sample of twenty-five (25) cash drawdown petitions for the Immunization Cooperative Agreement, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis. Effect Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions. Questioned Costs None Perspective Information Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe. Prior Year Audit Finding None Recommendation The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds. Views of responsible officials The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written procedures to ensure that payments are issued promptly after the drawdown is made. Responsible Officials Mrs. Camille Francisco Peguero Program Accountant 787-765-2929 ext. 3287 Dr. Angel M. Rivera Garcia Program Director 787-765-2929 ext. 3338 Estimated Completion Date The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-004 Agency: Department of Health & Human Services Federal Program: Immunization Cooperative Agreement ALN: 93.268 Grant Number: Various Compliance Requirement: Cash Management Category: Significant Deficiency in Internal Control over Compliance Criteria 2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. 2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition During our procedures, we found the following exceptions: a) In a sample of twenty-five (25) cash drawdown petitions for the Immunization Cooperative Agreement, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis. Effect Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions. Questioned Costs None Perspective Information Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe. Prior Year Audit Finding None Recommendation The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds. Views of responsible officials The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written procedures to ensure that payments are issued promptly after the drawdown is made. Responsible Officials Mrs. Camille Francisco Peguero Program Accountant 787-765-2929 ext. 3287 Dr. Angel M. Rivera Garcia Program Director 787-765-2929 ext. 3338 Estimated Completion Date The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-006 Agency: Department of Health & Human Services Federal Program: Epidemiology and Laboratory Capacity for Infectious Diseases ALN: 93.323 Grant Number: Various Compliance Requirement: Cash Management Category: Significant Deficiency in Internal Control over Compliance Criteria 2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. 2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition During our procedures, we found the following exceptions: a) In a sample of fifteen (25) cash drawdown petitions for Epidemiology and Laboratory Capacity for Infectious Diseases, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis. Effect Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions. Questioned Costs None Perspective Information Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe. Prior Year Audit Finding None Recommendation The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds. Views of responsible officials The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written internal procedures to ensure that payments are issued promptly after the drawdown is made. Responsible Officials Mrs. Sylvianette Luna Anavitate Program Director 787-765-2929 ext. 3121 Mr. Bryan Santos Martínez Financial and Accountant Analyst 787-765-2929 ext. 3361 Estimated Completion Date The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-006 Agency: Department of Health & Human Services Federal Program: Epidemiology and Laboratory Capacity for Infectious Diseases ALN: 93.323 Grant Number: Various Compliance Requirement: Cash Management Category: Significant Deficiency in Internal Control over Compliance Criteria 2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. 2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition During our procedures, we found the following exceptions: a) In a sample of fifteen (25) cash drawdown petitions for Epidemiology and Laboratory Capacity for Infectious Diseases, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis. Effect Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions. Questioned Costs None Perspective Information Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe. Prior Year Audit Finding None Recommendation The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds. Views of responsible officials The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written internal procedures to ensure that payments are issued promptly after the drawdown is made. Responsible Officials Mrs. Sylvianette Luna Anavitate Program Director 787-765-2929 ext. 3121 Mr. Bryan Santos Martínez Financial and Accountant Analyst 787-765-2929 ext. 3361 Estimated Completion Date The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-005 Agency: Department of Health & Human Services Federal Program: Maternal and Child Health Services Block Grant to the State ALN: 93.994 Grant Number: Various Compliance Requirement: Cash Management Category: Significant Deficiency in Internal Control over Compliance Criteria 2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. 2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition During our procedures, we found the following exceptions: a) In a sample of fifteen (25) cash drawdown petitions for Maternal and Child Health Services Block Grant to the State, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis. Effect Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions. Questioned Costs None Perspective Information Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe. Prior Year Audit Finding None Recommendation The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds. Views of responsible officials The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written procedures to ensure that payments are issued promptly after the drawdown is made. Responsible Officials Dr. Manuel Vargas Bernier Program Director 787-765-2929 ext. 4583 Mrs. Diana Ferrer Rivera Senior Accountant 787-765-2929 ext. 4551 Mrs. Lydia Magaly Cabrera Accountant 787-765-2929 ext. 4587 Estimated Completion Date The Completion date for the revised procedures will be by December 2025.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2024-002 Impact Aid Parent Pupil Surveys CFDA No: 84.041 Program Name: Impact Aid Award Number: N/A Federal Agency: U.S. Department of Education Pass-Through Grantor: N/A Compliance Requirement: L. Reporting Questioned Costs: N/A Summary of Finding: Material weakness in internal control over major programs Repeat Finding? No Condition The District reported 164 students within the Impact Aid application for the fiscal year 2024. The district provided 55 “Parent Pupil Surveys” which reflected 95 students total. Criteria The Uniform Guidance section 200.333 states: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report" 34 CFR 222.9 and .10 states: "An LEA must retain the records to support the amount of payment it received under the Act for any fiscal year until the later of (a) Three years after the last payment for a fiscal year; or (b) If the records have been questioned on Federal audit or review, until the question is finally resolved and any necessary adjustments to payments have been made." Cause The District experienced turnover in positions responsible for overseeing the single audit. Effect The District is not in compliance with the requirements of the Uniform Guidance and related federal grant federal regulations . Recommendation We recommend that the District aggregate and reconcile all application documentation. Then the District should scan all supporting documentation and place in a secured central location electronically and/or physically.
Finding #2024-001 – Inability to Produce Supporting Report to Confirm the Accuracy of the Verification Report Sample Condition: During the fiscal year ended June 30, 2024, the District was unable to provide a report that supported the accuracy of the verification report sample. This lack of documentation prevented us from verifying that the sample was appropriately selected and representative of the population, as required under federal regulations. Effect: The inability to confirm the accuracy and validity of the verification report sample compromises the reliability of compliance testing results. This creates a risk of noncompliance with federal program requirements and potential misreporting. Cause: The District transitioned to new software during the fiscal year and relied on the software to produce the sample without verifying the accuracy of the population data. Staff lacked an understanding of how the software selected samples and did not independently validate the sampling process. Criteria: Per 2 CFR § 200.333 (Retention requirements for records), recipients of federal awards must maintain adequate documentation to support financial and compliance-related activities. Additionally, accurate and reliable sampling procedures are critical for compliance with federal program requirements. Questioned Costs: None Recommendation: We recommend that the District implement a record retention policy that requires all supporting documentation for verification reports and samples to be maintained and reviewed for accuracy. We recommend that the District provide training to staff responsible for federal program compliance, emphasizing the importance of verifying population data and sampling processes. Obtain training from the software provider to ensure staff understand how the software generates samples and verify its accuracy. Establish a process for periodic internal reviews to confirm that all required documentation is retained and readily available for audit purposes. Response: The District agrees with the finding. During the fiscal year 2024, the District will obtain training from the software provider to ensure reports are accurate and will no longer rely solely on the system without validation.
Finding #2024-001 – Inability to Produce Supporting Report to Confirm the Accuracy of the Verification Report Sample Condition: During the fiscal year ended June 30, 2024, the District was unable to provide a report that supported the accuracy of the verification report sample. This lack of documentation prevented us from verifying that the sample was appropriately selected and representative of the population, as required under federal regulations. Effect: The inability to confirm the accuracy and validity of the verification report sample compromises the reliability of compliance testing results. This creates a risk of noncompliance with federal program requirements and potential misreporting. Cause: The District transitioned to new software during the fiscal year and relied on the software to produce the sample without verifying the accuracy of the population data. Staff lacked an understanding of how the software selected samples and did not independently validate the sampling process. Criteria: Per 2 CFR § 200.333 (Retention requirements for records), recipients of federal awards must maintain adequate documentation to support financial and compliance-related activities. Additionally, accurate and reliable sampling procedures are critical for compliance with federal program requirements. Questioned Costs: None Recommendation: We recommend that the District implement a record retention policy that requires all supporting documentation for verification reports and samples to be maintained and reviewed for accuracy. We recommend that the District provide training to staff responsible for federal program compliance, emphasizing the importance of verifying population data and sampling processes. Obtain training from the software provider to ensure staff understand how the software generates samples and verify its accuracy. Establish a process for periodic internal reviews to confirm that all required documentation is retained and readily available for audit purposes. Response: The District agrees with the finding. During the fiscal year 2024, the District will obtain training from the software provider to ensure reports are accurate and will no longer rely solely on the system without validation.
Finding #2024-001 – Inability to Produce Supporting Report to Confirm the Accuracy of the Verification Report Sample Condition: During the fiscal year ended June 30, 2024, the District was unable to provide a report that supported the accuracy of the verification report sample. This lack of documentation prevented us from verifying that the sample was appropriately selected and representative of the population, as required under federal regulations. Effect: The inability to confirm the accuracy and validity of the verification report sample compromises the reliability of compliance testing results. This creates a risk of noncompliance with federal program requirements and potential misreporting. Cause: The District transitioned to new software during the fiscal year and relied on the software to produce the sample without verifying the accuracy of the population data. Staff lacked an understanding of how the software selected samples and did not independently validate the sampling process. Criteria: Per 2 CFR § 200.333 (Retention requirements for records), recipients of federal awards must maintain adequate documentation to support financial and compliance-related activities. Additionally, accurate and reliable sampling procedures are critical for compliance with federal program requirements. Questioned Costs: None Recommendation: We recommend that the District implement a record retention policy that requires all supporting documentation for verification reports and samples to be maintained and reviewed for accuracy. We recommend that the District provide training to staff responsible for federal program compliance, emphasizing the importance of verifying population data and sampling processes. Obtain training from the software provider to ensure staff understand how the software generates samples and verify its accuracy. Establish a process for periodic internal reviews to confirm that all required documentation is retained and readily available for audit purposes. Response: The District agrees with the finding. During the fiscal year 2024, the District will obtain training from the software provider to ensure reports are accurate and will no longer rely solely on the system without validation.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers: S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Annual Report Card, High School Graduation Rate Audit Findings: Significant Deficiency Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain information from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or deceased." 2 CFR 200.333 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient..." 2 CFR 200.334 (Revised Uniform Guidance) states in part: “Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Cause: Management had not developed nor implemented a system of internal control that would have ensured compliance with the grant agreement and the Special Tests and Provisions compliance requirement. Effect: The failure to establish an effective internal control system could enable noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Annual Report Card, High School Graduation Rate compliance requirement could result in loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. There was no formal documented review of mobility reports in Skyward during our audit period. Identification as a repeat finding: This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Recommendation: We recommended that the School Corporation's management establish an effective system of internal control to ensure compliance and comply with the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers: S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Annual Report Card, High School Graduation Rate Audit Findings: Significant Deficiency Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain information from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or deceased." 2 CFR 200.333 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient..." 2 CFR 200.334 (Revised Uniform Guidance) states in part: “Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Cause: Management had not developed nor implemented a system of internal control that would have ensured compliance with the grant agreement and the Special Tests and Provisions compliance requirement. Effect: The failure to establish an effective internal control system could enable noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Annual Report Card, High School Graduation Rate compliance requirement could result in loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. There was no formal documented review of mobility reports in Skyward during our audit period. Identification as a repeat finding: This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Recommendation: We recommended that the School Corporation's management establish an effective system of internal control to ensure compliance and comply with the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers: S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Annual Report Card, High School Graduation Rate Audit Findings: Significant Deficiency Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain information from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or deceased." 2 CFR 200.333 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient..." 2 CFR 200.334 (Revised Uniform Guidance) states in part: “Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Cause: Management had not developed nor implemented a system of internal control that would have ensured compliance with the grant agreement and the Special Tests and Provisions compliance requirement. Effect: The failure to establish an effective internal control system could enable noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Annual Report Card, High School Graduation Rate compliance requirement could result in loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. There was no formal documented review of mobility reports in Skyward during our audit period. Identification as a repeat finding: This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Recommendation: We recommended that the School Corporation's management establish an effective system of internal control to ensure compliance and comply with the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding Number: 2024-004 Agency: Department of Health & Human Services Federal Program: Immunization Cooperative Agreement ALN: 93.268 Grant Number: Various Compliance Requirement: Cash Management Category: Significant Deficiency in Internal Control over Compliance Criteria 2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. 2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition During our procedures, we found the following exceptions: a) In a sample of twenty-five (25) cash drawdown petitions for the Immunization Cooperative Agreement, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis. Effect Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions. Questioned Costs None Perspective Information Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe. Prior Year Audit Finding None Recommendation The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds. Views of responsible officials The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written procedures to ensure that payments are issued promptly after the drawdown is made. Responsible Officials Mrs. Camille Francisco Peguero Program Accountant 787-765-2929 ext. 3287 Dr. Angel M. Rivera Garcia Program Director 787-765-2929 ext. 3338 Estimated Completion Date The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-004 Agency: Department of Health & Human Services Federal Program: Immunization Cooperative Agreement ALN: 93.268 Grant Number: Various Compliance Requirement: Cash Management Category: Significant Deficiency in Internal Control over Compliance Criteria 2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. 2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition During our procedures, we found the following exceptions: a) In a sample of twenty-five (25) cash drawdown petitions for the Immunization Cooperative Agreement, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis. Effect Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions. Questioned Costs None Perspective Information Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe. Prior Year Audit Finding None Recommendation The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds. Views of responsible officials The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written procedures to ensure that payments are issued promptly after the drawdown is made. Responsible Officials Mrs. Camille Francisco Peguero Program Accountant 787-765-2929 ext. 3287 Dr. Angel M. Rivera Garcia Program Director 787-765-2929 ext. 3338 Estimated Completion Date The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-006 Agency: Department of Health & Human Services Federal Program: Epidemiology and Laboratory Capacity for Infectious Diseases ALN: 93.323 Grant Number: Various Compliance Requirement: Cash Management Category: Significant Deficiency in Internal Control over Compliance Criteria 2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. 2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition During our procedures, we found the following exceptions: a) In a sample of fifteen (25) cash drawdown petitions for Epidemiology and Laboratory Capacity for Infectious Diseases, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis. Effect Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions. Questioned Costs None Perspective Information Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe. Prior Year Audit Finding None Recommendation The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds. Views of responsible officials The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written internal procedures to ensure that payments are issued promptly after the drawdown is made. Responsible Officials Mrs. Sylvianette Luna Anavitate Program Director 787-765-2929 ext. 3121 Mr. Bryan Santos Martínez Financial and Accountant Analyst 787-765-2929 ext. 3361 Estimated Completion Date The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-006 Agency: Department of Health & Human Services Federal Program: Epidemiology and Laboratory Capacity for Infectious Diseases ALN: 93.323 Grant Number: Various Compliance Requirement: Cash Management Category: Significant Deficiency in Internal Control over Compliance Criteria 2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. 2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition During our procedures, we found the following exceptions: a) In a sample of fifteen (25) cash drawdown petitions for Epidemiology and Laboratory Capacity for Infectious Diseases, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis. Effect Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions. Questioned Costs None Perspective Information Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe. Prior Year Audit Finding None Recommendation The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds. Views of responsible officials The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written internal procedures to ensure that payments are issued promptly after the drawdown is made. Responsible Officials Mrs. Sylvianette Luna Anavitate Program Director 787-765-2929 ext. 3121 Mr. Bryan Santos Martínez Financial and Accountant Analyst 787-765-2929 ext. 3361 Estimated Completion Date The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-005 Agency: Department of Health & Human Services Federal Program: Maternal and Child Health Services Block Grant to the State ALN: 93.994 Grant Number: Various Compliance Requirement: Cash Management Category: Significant Deficiency in Internal Control over Compliance Criteria 2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. 2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition During our procedures, we found the following exceptions: a) In a sample of fifteen (25) cash drawdown petitions for Maternal and Child Health Services Block Grant to the State, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis. Effect Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions. Questioned Costs None Perspective Information Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe. Prior Year Audit Finding None Recommendation The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds. Views of responsible officials The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written procedures to ensure that payments are issued promptly after the drawdown is made. Responsible Officials Dr. Manuel Vargas Bernier Program Director 787-765-2929 ext. 4583 Mrs. Diana Ferrer Rivera Senior Accountant 787-765-2929 ext. 4551 Mrs. Lydia Magaly Cabrera Accountant 787-765-2929 ext. 4587 Estimated Completion Date The Completion date for the revised procedures will be by December 2025.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2024-002 Impact Aid Parent Pupil Surveys CFDA No: 84.041 Program Name: Impact Aid Award Number: N/A Federal Agency: U.S. Department of Education Pass-Through Grantor: N/A Compliance Requirement: L. Reporting Questioned Costs: N/A Summary of Finding: Material weakness in internal control over major programs Repeat Finding? No Condition The District reported 164 students within the Impact Aid application for the fiscal year 2024. The district provided 55 “Parent Pupil Surveys” which reflected 95 students total. Criteria The Uniform Guidance section 200.333 states: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report" 34 CFR 222.9 and .10 states: "An LEA must retain the records to support the amount of payment it received under the Act for any fiscal year until the later of (a) Three years after the last payment for a fiscal year; or (b) If the records have been questioned on Federal audit or review, until the question is finally resolved and any necessary adjustments to payments have been made." Cause The District experienced turnover in positions responsible for overseeing the single audit. Effect The District is not in compliance with the requirements of the Uniform Guidance and related federal grant federal regulations . Recommendation We recommend that the District aggregate and reconcile all application documentation. Then the District should scan all supporting documentation and place in a secured central location electronically and/or physically.
Finding Number: 2023-035 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: Government Department/Agency: U.S. Department of Health and Human Services Opioid STR ALN: 93.788 Award #: Various Award Year: 09/30/2020 – 09/29/2024 Department of Behavioral Health (DBH) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Federal Awardee Performance and Integrity Information System (FAPIIS) Reporting Compliance: In accordance with the regulatory requirements provided at 45 CFR 75.113 and Appendix XII to 45 CFR Part 75, recipients that have currently active Federal grants, cooperative agreements, and procurement contracts with cumulative total value greater than $10,000,000 must report and maintain information in the System for Award Management (SAM) about civil, criminal, and administrative proceedings in connection with the award or performance of a Federal award that reached final disposition within the most recent five-year period or affirm that there is no new information to report. The recipient must also make semiannual disclosures regarding such proceedings. Proceedings information will be made publicly available in the designated integrity and performance system (currently the FAPIIS). Federal Funding Accountability and Transparency Act (FFATA) Reporting Compliance: The FFATA (Pub. L. No. 109-282, as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170) requires prime recipients of federal awards who make first-tier subawards to report the subaward on the Federal Funding Accountability and Transparency Subaward Reporting System (FSRS) website maintained by the federal Office of Management and Budget. Under the requirements of 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more on the FSRS website. Prime recipients must report by the end of the month following the month in which the obligation is made. It is management’s responsibility to design and implement internal controls to reasonably ensure compliance with laws and regulations and to ensure management’s objectives are achieved. Federal Financial Report (FFR) Controls over Reporting Compliance: In addition, 2 CFR 200.333 requires that financial records, supporting documents, statistical records, and all other non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the federal awarding agency or pass-through entity in the case of a subrecipient. Performance Progress Report (PPR) Underlying Data: The audit objective for the Reporting compliance requirement stated in the 2 CFR Part 200, appendix XI Compliance Supplement is as follows: Determine whether required reports for Federal awards include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. Schedule of Expenditures of Federal Awards (SEFA) Reporting Compliance: Requirements, Cost Principles, and Audit Requirements, section 200.510(b) states the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. Condition – During our testing of the reporting compliance requirement, we noted the following: • FAPIIS Reporting Compliance: During our testing of FAPIIS reporting for fiscal year ended September 30, 2023, it was noted that the program’s reporting regarding civil, criminal, and administrative proceedings in connection with the award or performance of a Federal award that reached final disposition within the most recent five-year period or affirmation that there was no new information to report was not submitted by the DBH program management. • FFATA Reporting Compliance: During our testing of FFATA reporting, it was noted that reports were not submitted by the DBH program management. DBH program management was not aware of FFATA reporting requirement and did not report subawards within the FSRS website during the award year. None of the ten subawards selected for testing were reported to FSRS. Total subawards tested were $3,559,912, and $0 was reported as required by FFATA requirements. • FFR Controls over Reporting Compliance: DBH’s control over compliance for financial reporting is as follows: “All reports are reviewed by the Accounting Officer or Agency Fiscal Officer prior to submission to the Federal government. DBH Program and Fiscal Services staff review programmatic and financial reports.” We noted DBH did not have documentation of the control over compliance, as well as the review and approval of the Financial Reporting Report (FFR or SF-425). • PPR Reporting Compliance: We found DBH did not have documentation for the information, and the source of the information, it used in its Opioid program’s Performance Progress Report. Information as reported on the reports is unsupported as management did not retain the underlying data. • SEFA Reporting Compliance: During our testing for the SEFA, we noted that DBH incorrectly reported the value of subrecipient expenditures included within the subrecipient expenditure column. For the year ended September 30, 2023, DBH incurred $12,800,130 in subrecipient expenditures for this program and incorrectly reported that there were no subrecipient expenditures on the draft SEFA. The error was subsequently identified and corrected as a result of the audit process. While the subrecipient expenditure column was not accurate, the total expenditure column was accurately reported. Questioned Costs – None. Context – This is a condition identified per review of DBH’s compliance with specified reporting requirements using a statistically valid sample. Effect – Without proper internal controls and policies and procedures in place to ensure that correct amounts were reported and were properly reviewed, the Opioid STR program: • FAPIIS Reporting Compliance: DBH management did not report the necessary FAPIIS information for Opioid STR in accordance with Federal requirements. • FFATA Reporting Compliance: DBH management did not report the necessary FFATA report for Opioid STR first-tier subawards over $30,000 to the FFATA Subaward Reporting System in accordance with FFATA requirements. • FFR Controls over Reporting Compliance: There is an increased risk of errors occurring and going undetected, or errors being present in reports if no review and approval occurred. • PPR Reporting Compliance: DBH cannot be assured that it reported complete and accurate information to enable the Substance Abuse and Mental Health Services Administration (SAMHSA), an operating division of the Department of Health and Human Services (HHS), to assess the outcomes of the State’s use of Opioid program funding. • SEFA Reporting Compliance: The effect of the condition found is that the SEFA was not accurately prepared. Cause – Management did not have proper internal controls and policies and procedures in place to ensure that the amounts on the FAPIIS, FFATA, FFR, PPR and SEFA were properly reported, and the reports were properly reviewed and approved. Recommendation – We recommend the following: • FAPIIS Reporting Compliance: We recommend DBH to evaluate its reporting control procedures and update them as necessary to ensure they promote compliance with the Federal regulations. These procedures should include a supervisory review of the report information before it is submitted. Further, we recommend that DBH collect, and report complete and accurate information regarding FAPIIS. • FFATA Reporting Compliance: We recommend DBH to evaluate its Transparency Act reporting control procedures and update them as necessary to ensure they promote compliance with the Federal regulations. These procedures should include a supervisory review of the report information before it is submitted on the FSRS website. Further, we recommend DBH collect and report on the FSRS website complete and accurate information regarding subawards made for all programs subject to the Transparency Act. • FFR Controls over Reporting Compliance: We recommend DBH to design and implement procedures to ensure sufficient documentation is maintained that supports the review and approval of the FFR. • PPR Reporting Compliance: We recommend DBH to develop formal, written procedures to identify the sources of information necessary and steps needed to compile accurate and complete information for the Opioid program performance reports; and retain in a central location all documentation that it used to support information included in each performance report it submits to the federal government. • SEFA Reporting Compliance: We recommend DBH to ensure that agency personnel receive proper training on subrecipient versus vendor determination; as well as review its existing policies and procedures for preparing the Schedule of Expenditures of Federal Awards to ensure that it is complete and accurate. Related Noncompliance – Material noncompliance. Views of Responsible Officials and Planned Corrective Actions – DBH agrees with these findings and plans to address reporting requirements to ensure that the FAPIIS, FFATA, FFR, PPR and SEFA are completed accurately and on the required schedule. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.
Finding Number: 2023-035 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: Government Department/Agency: U.S. Department of Health and Human Services Opioid STR ALN: 93.788 Award #: Various Award Year: 09/30/2020 – 09/29/2024 Department of Behavioral Health (DBH) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Federal Awardee Performance and Integrity Information System (FAPIIS) Reporting Compliance: In accordance with the regulatory requirements provided at 45 CFR 75.113 and Appendix XII to 45 CFR Part 75, recipients that have currently active Federal grants, cooperative agreements, and procurement contracts with cumulative total value greater than $10,000,000 must report and maintain information in the System for Award Management (SAM) about civil, criminal, and administrative proceedings in connection with the award or performance of a Federal award that reached final disposition within the most recent five-year period or affirm that there is no new information to report. The recipient must also make semiannual disclosures regarding such proceedings. Proceedings information will be made publicly available in the designated integrity and performance system (currently the FAPIIS). Federal Funding Accountability and Transparency Act (FFATA) Reporting Compliance: The FFATA (Pub. L. No. 109-282, as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170) requires prime recipients of federal awards who make first-tier subawards to report the subaward on the Federal Funding Accountability and Transparency Subaward Reporting System (FSRS) website maintained by the federal Office of Management and Budget. Under the requirements of 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more on the FSRS website. Prime recipients must report by the end of the month following the month in which the obligation is made. It is management’s responsibility to design and implement internal controls to reasonably ensure compliance with laws and regulations and to ensure management’s objectives are achieved. Federal Financial Report (FFR) Controls over Reporting Compliance: In addition, 2 CFR 200.333 requires that financial records, supporting documents, statistical records, and all other non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the federal awarding agency or pass-through entity in the case of a subrecipient. Performance Progress Report (PPR) Underlying Data: The audit objective for the Reporting compliance requirement stated in the 2 CFR Part 200, appendix XI Compliance Supplement is as follows: Determine whether required reports for Federal awards include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. Schedule of Expenditures of Federal Awards (SEFA) Reporting Compliance: Requirements, Cost Principles, and Audit Requirements, section 200.510(b) states the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. Condition – During our testing of the reporting compliance requirement, we noted the following: • FAPIIS Reporting Compliance: During our testing of FAPIIS reporting for fiscal year ended September 30, 2023, it was noted that the program’s reporting regarding civil, criminal, and administrative proceedings in connection with the award or performance of a Federal award that reached final disposition within the most recent five-year period or affirmation that there was no new information to report was not submitted by the DBH program management. • FFATA Reporting Compliance: During our testing of FFATA reporting, it was noted that reports were not submitted by the DBH program management. DBH program management was not aware of FFATA reporting requirement and did not report subawards within the FSRS website during the award year. None of the ten subawards selected for testing were reported to FSRS. Total subawards tested were $3,559,912, and $0 was reported as required by FFATA requirements. • FFR Controls over Reporting Compliance: DBH’s control over compliance for financial reporting is as follows: “All reports are reviewed by the Accounting Officer or Agency Fiscal Officer prior to submission to the Federal government. DBH Program and Fiscal Services staff review programmatic and financial reports.” We noted DBH did not have documentation of the control over compliance, as well as the review and approval of the Financial Reporting Report (FFR or SF-425). • PPR Reporting Compliance: We found DBH did not have documentation for the information, and the source of the information, it used in its Opioid program’s Performance Progress Report. Information as reported on the reports is unsupported as management did not retain the underlying data. • SEFA Reporting Compliance: During our testing for the SEFA, we noted that DBH incorrectly reported the value of subrecipient expenditures included within the subrecipient expenditure column. For the year ended September 30, 2023, DBH incurred $12,800,130 in subrecipient expenditures for this program and incorrectly reported that there were no subrecipient expenditures on the draft SEFA. The error was subsequently identified and corrected as a result of the audit process. While the subrecipient expenditure column was not accurate, the total expenditure column was accurately reported. Questioned Costs – None. Context – This is a condition identified per review of DBH’s compliance with specified reporting requirements using a statistically valid sample. Effect – Without proper internal controls and policies and procedures in place to ensure that correct amounts were reported and were properly reviewed, the Opioid STR program: • FAPIIS Reporting Compliance: DBH management did not report the necessary FAPIIS information for Opioid STR in accordance with Federal requirements. • FFATA Reporting Compliance: DBH management did not report the necessary FFATA report for Opioid STR first-tier subawards over $30,000 to the FFATA Subaward Reporting System in accordance with FFATA requirements. • FFR Controls over Reporting Compliance: There is an increased risk of errors occurring and going undetected, or errors being present in reports if no review and approval occurred. • PPR Reporting Compliance: DBH cannot be assured that it reported complete and accurate information to enable the Substance Abuse and Mental Health Services Administration (SAMHSA), an operating division of the Department of Health and Human Services (HHS), to assess the outcomes of the State’s use of Opioid program funding. • SEFA Reporting Compliance: The effect of the condition found is that the SEFA was not accurately prepared. Cause – Management did not have proper internal controls and policies and procedures in place to ensure that the amounts on the FAPIIS, FFATA, FFR, PPR and SEFA were properly reported, and the reports were properly reviewed and approved. Recommendation – We recommend the following: • FAPIIS Reporting Compliance: We recommend DBH to evaluate its reporting control procedures and update them as necessary to ensure they promote compliance with the Federal regulations. These procedures should include a supervisory review of the report information before it is submitted. Further, we recommend that DBH collect, and report complete and accurate information regarding FAPIIS. • FFATA Reporting Compliance: We recommend DBH to evaluate its Transparency Act reporting control procedures and update them as necessary to ensure they promote compliance with the Federal regulations. These procedures should include a supervisory review of the report information before it is submitted on the FSRS website. Further, we recommend DBH collect and report on the FSRS website complete and accurate information regarding subawards made for all programs subject to the Transparency Act. • FFR Controls over Reporting Compliance: We recommend DBH to design and implement procedures to ensure sufficient documentation is maintained that supports the review and approval of the FFR. • PPR Reporting Compliance: We recommend DBH to develop formal, written procedures to identify the sources of information necessary and steps needed to compile accurate and complete information for the Opioid program performance reports; and retain in a central location all documentation that it used to support information included in each performance report it submits to the federal government. • SEFA Reporting Compliance: We recommend DBH to ensure that agency personnel receive proper training on subrecipient versus vendor determination; as well as review its existing policies and procedures for preparing the Schedule of Expenditures of Federal Awards to ensure that it is complete and accurate. Related Noncompliance – Material noncompliance. Views of Responsible Officials and Planned Corrective Actions – DBH agrees with these findings and plans to address reporting requirements to ensure that the FAPIIS, FFATA, FFR, PPR and SEFA are completed accurately and on the required schedule. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.
Information on the Federal Program: Assistance Listing Number 10.561— State Administrative Matching Grants for Supplemental Nutrition Assistance Program, United States Department of Agriculture. Pass-Through Entity: Colorado Department of Human Services. Compliance Requirements: Allowable Cost and Activities. Type of Finding: Material Noncompliance and Significant Deficiency Criteria: Program requirements state that each program participants file should follow the record retention policies contained in the grant agreementand required under 2 CFR §200.333, to support conclusion on program eligibility. Condition: For the year ended June 30, 2023, we identified one program participant file that was not retained, and were unable to confirm if program participant was eligible, and services provided were supported in file. Cause: Program staff upon termination misplaced file, and it was unable to be tracked down during audit. Effect or Potential Effect: As a result, we were not able to verify program eligibility or if services provided were supported and allowable under the program for missing file. Questioned Costs: None. Context: Of the sixty participant files tested, we identified one that was not retained and available to review. Recommendation: The entity program staff and management should ensure record retention policies are enforced. Views of Responsible : We agree with the auditor’s finding that there was no documentation available to substantiate eligibility, however we believe our actions meet the requirements of the program. While we understand that documentation should be maintained, we do believe that the services provided were in compliance with applicable standards.
Finding 2023-003 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions Identification of the federal program: Federal Grantor: United States Department of Homeland Security Pass-Through Grantors: State of Missouri, State Emergency Management Agency Arkansas Division of Emergency Management Assistance Listing No.: 97.036, COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Award Numbers and Award Periods: Project# 185883 P/W# 529 01/20/2020–09/14/2020 Project# 699963 P/W# 624 01/01/2022–07/01/2022 Project# 699667 P/W# 233 01/01/2022–07/01/2022 Project# 699670 P/W# 211 01/01/2022–07/01/2022 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” As described in Title 2 Code of Federal Regulations (C.F.R.) § 200.333, financial records, supporting documents, statistical records and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three (3) years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. In addition, 2 CFR Section 200.403 of the Uniform Guidance states the following regarding the factors affecting the allowability of costs: “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented.” Condition: Adequate documentation was not retained to support the average unit cost applied to COVID-19 personal protective equipment (PPE) inventory usage charged to the FEMA program as Force Account Material (FAM) costs. In addition, for 12 of 40 non-FAM costs (including purchased equipment, purchased supplies, and rental equipment) charged to the program, we noted adequate documentation was not retained to evidence review and approval of the expenditure for allowability. Cause: Management did not have sufficiently designed internal controls in place over the review and approval of average unit costs applied to FAM usage charged to the FEMA program. In addition, for 11 non-FAM (purchased equipment) transactions from fiscal year 2020 charged to the FEMA program, expenditure approvals were maintained in a legacy general ledger system and upon migration to the current general ledger system, the approval trail was not retained. For one other non-FAM (purchased equipment) transaction from fiscal year 2022 charged to the FEMA program, the required level of approvals of the purchase-card transaction was not retained. Effect or potential effect: For FAM costs, Mercy Health is not in compliance with the general criteria of maintaining adequate documentation that supports the average unit costs used in the calculation and determination of the costs charged to the federal program. For non-FAM costs, Mercy Health may not be compliant with the allowability of costs requirements of the FEMA program. Questioned costs: $45 – Assistance Listing No. 97.036 (COVID-19). Context: We sampled 40 FAM costs (totaling $2,826 in federal expenditures) and agreed the PPE inventory item’s usage to supporting requisition documentation. In addition, we obtained the external vendor invoice for the purchase of the PPE inventory item immediately prior to the usage of the PPE inventory item. However, for all 40 sampled FAM costs, we could not verify the average unit cost that is used in determining the amount charged to the FEMA program. The net overstatement of the costs based on the average unit cost for these 40 sampled FAM costs in comparison to the external vendor invoices was $45. In addition, we sampled 40 non-FAM costs (totaling $218,110 in federal expenditures) and noted that 12 purchased equipment transactions (totaling $182,048 in federal expenditures) did not have support retained to evidence review and approval of the expenditure for allowability. FAM costs and non-FAM costs represent 71% and 29%, respectively, of total federal expenditures for the FEMA program of $3,383,897 for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should design and implement effective internal controls over the review and approval of all costs charged to the FEMA program. Views of Responsible Officials: Mercy Health has a system to calculate average cost of inventory items. We rely on this system, but it was not tested as part of compliance. In addition, Mercy Health has a robust capital approval process (for all equipment) and financial approval thresholds. All COVID purchases were logged in the capital system (VFA) and approvals were documented. During this time, we changed approval systems from VFA to Strata. We will ensure all capital is reviewed and approved in Strata going forward.
Finding 2023-003 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions Identification of the federal program: Federal Grantor: United States Department of Homeland Security Pass-Through Grantors: State of Missouri, State Emergency Management Agency Arkansas Division of Emergency Management Assistance Listing No.: 97.036, COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Award Numbers and Award Periods: Project# 185883 P/W# 529 01/20/2020–09/14/2020 Project# 699963 P/W# 624 01/01/2022–07/01/2022 Project# 699667 P/W# 233 01/01/2022–07/01/2022 Project# 699670 P/W# 211 01/01/2022–07/01/2022 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” As described in Title 2 Code of Federal Regulations (C.F.R.) § 200.333, financial records, supporting documents, statistical records and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three (3) years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. In addition, 2 CFR Section 200.403 of the Uniform Guidance states the following regarding the factors affecting the allowability of costs: “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented.” Condition: Adequate documentation was not retained to support the average unit cost applied to COVID-19 personal protective equipment (PPE) inventory usage charged to the FEMA program as Force Account Material (FAM) costs. In addition, for 12 of 40 non-FAM costs (including purchased equipment, purchased supplies, and rental equipment) charged to the program, we noted adequate documentation was not retained to evidence review and approval of the expenditure for allowability. Cause: Management did not have sufficiently designed internal controls in place over the review and approval of average unit costs applied to FAM usage charged to the FEMA program. In addition, for 11 non-FAM (purchased equipment) transactions from fiscal year 2020 charged to the FEMA program, expenditure approvals were maintained in a legacy general ledger system and upon migration to the current general ledger system, the approval trail was not retained. For one other non-FAM (purchased equipment) transaction from fiscal year 2022 charged to the FEMA program, the required level of approvals of the purchase-card transaction was not retained. Effect or potential effect: For FAM costs, Mercy Health is not in compliance with the general criteria of maintaining adequate documentation that supports the average unit costs used in the calculation and determination of the costs charged to the federal program. For non-FAM costs, Mercy Health may not be compliant with the allowability of costs requirements of the FEMA program. Questioned costs: $45 – Assistance Listing No. 97.036 (COVID-19). Context: We sampled 40 FAM costs (totaling $2,826 in federal expenditures) and agreed the PPE inventory item’s usage to supporting requisition documentation. In addition, we obtained the external vendor invoice for the purchase of the PPE inventory item immediately prior to the usage of the PPE inventory item. However, for all 40 sampled FAM costs, we could not verify the average unit cost that is used in determining the amount charged to the FEMA program. The net overstatement of the costs based on the average unit cost for these 40 sampled FAM costs in comparison to the external vendor invoices was $45. In addition, we sampled 40 non-FAM costs (totaling $218,110 in federal expenditures) and noted that 12 purchased equipment transactions (totaling $182,048 in federal expenditures) did not have support retained to evidence review and approval of the expenditure for allowability. FAM costs and non-FAM costs represent 71% and 29%, respectively, of total federal expenditures for the FEMA program of $3,383,897 for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should design and implement effective internal controls over the review and approval of all costs charged to the FEMA program. Views of Responsible Officials: Mercy Health has a system to calculate average cost of inventory items. We rely on this system, but it was not tested as part of compliance. In addition, Mercy Health has a robust capital approval process (for all equipment) and financial approval thresholds. All COVID purchases were logged in the capital system (VFA) and approvals were documented. During this time, we changed approval systems from VFA to Strata. We will ensure all capital is reviewed and approved in Strata going forward.
Finding 2023-003 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions Identification of the federal program: Federal Grantor: United States Department of Homeland Security Pass-Through Grantors: State of Missouri, State Emergency Management Agency Arkansas Division of Emergency Management Assistance Listing No.: 97.036, COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Award Numbers and Award Periods: Project# 185883 P/W# 529 01/20/2020–09/14/2020 Project# 699963 P/W# 624 01/01/2022–07/01/2022 Project# 699667 P/W# 233 01/01/2022–07/01/2022 Project# 699670 P/W# 211 01/01/2022–07/01/2022 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” As described in Title 2 Code of Federal Regulations (C.F.R.) § 200.333, financial records, supporting documents, statistical records and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three (3) years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. In addition, 2 CFR Section 200.403 of the Uniform Guidance states the following regarding the factors affecting the allowability of costs: “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented.” Condition: Adequate documentation was not retained to support the average unit cost applied to COVID-19 personal protective equipment (PPE) inventory usage charged to the FEMA program as Force Account Material (FAM) costs. In addition, for 12 of 40 non-FAM costs (including purchased equipment, purchased supplies, and rental equipment) charged to the program, we noted adequate documentation was not retained to evidence review and approval of the expenditure for allowability. Cause: Management did not have sufficiently designed internal controls in place over the review and approval of average unit costs applied to FAM usage charged to the FEMA program. In addition, for 11 non-FAM (purchased equipment) transactions from fiscal year 2020 charged to the FEMA program, expenditure approvals were maintained in a legacy general ledger system and upon migration to the current general ledger system, the approval trail was not retained. For one other non-FAM (purchased equipment) transaction from fiscal year 2022 charged to the FEMA program, the required level of approvals of the purchase-card transaction was not retained. Effect or potential effect: For FAM costs, Mercy Health is not in compliance with the general criteria of maintaining adequate documentation that supports the average unit costs used in the calculation and determination of the costs charged to the federal program. For non-FAM costs, Mercy Health may not be compliant with the allowability of costs requirements of the FEMA program. Questioned costs: $45 – Assistance Listing No. 97.036 (COVID-19). Context: We sampled 40 FAM costs (totaling $2,826 in federal expenditures) and agreed the PPE inventory item’s usage to supporting requisition documentation. In addition, we obtained the external vendor invoice for the purchase of the PPE inventory item immediately prior to the usage of the PPE inventory item. However, for all 40 sampled FAM costs, we could not verify the average unit cost that is used in determining the amount charged to the FEMA program. The net overstatement of the costs based on the average unit cost for these 40 sampled FAM costs in comparison to the external vendor invoices was $45. In addition, we sampled 40 non-FAM costs (totaling $218,110 in federal expenditures) and noted that 12 purchased equipment transactions (totaling $182,048 in federal expenditures) did not have support retained to evidence review and approval of the expenditure for allowability. FAM costs and non-FAM costs represent 71% and 29%, respectively, of total federal expenditures for the FEMA program of $3,383,897 for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should design and implement effective internal controls over the review and approval of all costs charged to the FEMA program. Views of Responsible Officials: Mercy Health has a system to calculate average cost of inventory items. We rely on this system, but it was not tested as part of compliance. In addition, Mercy Health has a robust capital approval process (for all equipment) and financial approval thresholds. All COVID purchases were logged in the capital system (VFA) and approvals were documented. During this time, we changed approval systems from VFA to Strata. We will ensure all capital is reviewed and approved in Strata going forward.
Finding 2023-003 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions Identification of the federal program: Federal Grantor: United States Department of Homeland Security Pass-Through Grantors: State of Missouri, State Emergency Management Agency Arkansas Division of Emergency Management Assistance Listing No.: 97.036, COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Award Numbers and Award Periods: Project# 185883 P/W# 529 01/20/2020–09/14/2020 Project# 699963 P/W# 624 01/01/2022–07/01/2022 Project# 699667 P/W# 233 01/01/2022–07/01/2022 Project# 699670 P/W# 211 01/01/2022–07/01/2022 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” As described in Title 2 Code of Federal Regulations (C.F.R.) § 200.333, financial records, supporting documents, statistical records and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three (3) years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. In addition, 2 CFR Section 200.403 of the Uniform Guidance states the following regarding the factors affecting the allowability of costs: “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented.” Condition: Adequate documentation was not retained to support the average unit cost applied to COVID-19 personal protective equipment (PPE) inventory usage charged to the FEMA program as Force Account Material (FAM) costs. In addition, for 12 of 40 non-FAM costs (including purchased equipment, purchased supplies, and rental equipment) charged to the program, we noted adequate documentation was not retained to evidence review and approval of the expenditure for allowability. Cause: Management did not have sufficiently designed internal controls in place over the review and approval of average unit costs applied to FAM usage charged to the FEMA program. In addition, for 11 non-FAM (purchased equipment) transactions from fiscal year 2020 charged to the FEMA program, expenditure approvals were maintained in a legacy general ledger system and upon migration to the current general ledger system, the approval trail was not retained. For one other non-FAM (purchased equipment) transaction from fiscal year 2022 charged to the FEMA program, the required level of approvals of the purchase-card transaction was not retained. Effect or potential effect: For FAM costs, Mercy Health is not in compliance with the general criteria of maintaining adequate documentation that supports the average unit costs used in the calculation and determination of the costs charged to the federal program. For non-FAM costs, Mercy Health may not be compliant with the allowability of costs requirements of the FEMA program. Questioned costs: $45 – Assistance Listing No. 97.036 (COVID-19). Context: We sampled 40 FAM costs (totaling $2,826 in federal expenditures) and agreed the PPE inventory item’s usage to supporting requisition documentation. In addition, we obtained the external vendor invoice for the purchase of the PPE inventory item immediately prior to the usage of the PPE inventory item. However, for all 40 sampled FAM costs, we could not verify the average unit cost that is used in determining the amount charged to the FEMA program. The net overstatement of the costs based on the average unit cost for these 40 sampled FAM costs in comparison to the external vendor invoices was $45. In addition, we sampled 40 non-FAM costs (totaling $218,110 in federal expenditures) and noted that 12 purchased equipment transactions (totaling $182,048 in federal expenditures) did not have support retained to evidence review and approval of the expenditure for allowability. FAM costs and non-FAM costs represent 71% and 29%, respectively, of total federal expenditures for the FEMA program of $3,383,897 for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should design and implement effective internal controls over the review and approval of all costs charged to the FEMA program. Views of Responsible Officials: Mercy Health has a system to calculate average cost of inventory items. We rely on this system, but it was not tested as part of compliance. In addition, Mercy Health has a robust capital approval process (for all equipment) and financial approval thresholds. All COVID purchases were logged in the capital system (VFA) and approvals were documented. During this time, we changed approval systems from VFA to Strata. We will ensure all capital is reviewed and approved in Strata going forward.
Condition Two employees were paid wages for activities coded to special education: For one of the two special education employees tested, Ha:San prepared an employment contract, however, they were not signed by the employee or a school administrator. For the other employee tested, Ha:San could not provide evidence it prepared or retained an employment contract to support the employee designation to provide special education services. For all seven timecards tested for both employees the timecards did not contain a signature from either the employee or a School administrator. Criteria Accounting best practices specifies that supporting documentation should be prepared and retained to support all transactions. The Internal Revenue Service explains "An exempt organization must keep books and records needed to show that it complies with the tax rules. The organization must be able to document the sources of receipts and expenditures reported on its annual return and on any tax returns it must file. Records must support income, expenses, and credits reported on exempt organization annual returns and tax returns." Uniform Guidance §200.333 Retention requirements for records states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report..."must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. 2 CFR 200.430(i)(1)(vii) states: "Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are located using different allocation bases; or an unallowable activity and a direct or indirect cost activity." Cause There was a period of significant turnover in the administrative office for the past year. During the transition, existing controls were not followed to ensure complete documentation was retained. Effect Financial information Ha:San uses to make decisions and reports provided to the state of Arizona for oversight could have been materially misstated throughout the fiscal year. Further, Ha:San could end up being in noncompliance with federal and state laws. Recommendation Ha:San should procure a consultant or modify the organizational chart of the finance office to ensure individuals with the skills, knowledge and expertise prepare, review and retain required source documentation.
Federal Agency: U.S. Department of Commerce Federal Program: Economic Development Cluster Assistance Listing 11.307 COVID-19–Economic Adjustment Assistance EDA Award No. 08-79-05412 Criteria or specific requirement: Subrecipient Monitoring (2 CFR 200.331 - 200.333) and Reporting (2 CFR Part 170). Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: The Organization subawarded a portion of this award with out written approval from the Economic Development Administration. The Organization also failed to file the FFATA reporting submission for the fiscal year ended June 30, 2023. Questioned Costs: $215,000 Context: The Organization did not obtain approval or report the subaward information for the one subrecipient that received $215,000 in fiscal year 2023. Effect: The noncompliance could have a direct and material effect on the financial statements. Cause: The Organization did not have adequate controls or procedures in place to identify the applicable subrecipient monitoring and reporting requirements and ensure the information was filed accurately and timely. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend implementing procedures and controls to ensure subrecipient monitoring and reporting requirements are monitored and required reports are filed by their respective due dates as required by the grant agreement and Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation. See separate report for planned corrective actions.