SNAP-Ed Record Retention Information on the Federal Program: SNAP Cluster (AL Number 10.561) – U.S. Department of Agriculture Criteria: 2 CFR Section 200.334 - 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. State of Kentucky guidance per award number SC7362000001287 and SC362200001080 – the University must submit monthly and quarterly reports to the DCBS Division of Family Support, Director's office. Condition: Monthly and quarterly reports required to be submitted by the University to the State were not adequately retained during the required three-year period beginning July 1, 2021. Questioned Cost: $-0- Cause: The University did not have the proper internal controls in place to ensure that all required reporting documents were retained during the specified three-year period. Effect: Monthly and quarterly reporting for all periods were not available to be audited. Recommendation: We recommend the University review the internal controls over the administration of federal funds to ensure documentation is created and retained in accordance with federal and pass-through requirements.
SNAP-Ed Record Retention Information on the Federal Program: SNAP Cluster (AL Number 10.561) – U.S. Department of Agriculture Criteria: 2 CFR Section 200.334 - 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. State of Kentucky guidance per award number SC7362000001287 and SC362200001080 – the University must submit monthly and quarterly reports to the DCBS Division of Family Support, Director's office. Condition: Monthly and quarterly reports required to be submitted by the University to the State were not adequately retained during the required three-year period beginning July 1, 2021. Questioned Cost: $-0- Cause: The University did not have the proper internal controls in place to ensure that all required reporting documents were retained during the specified three-year period. Effect: Monthly and quarterly reporting for all periods were not available to be audited. Recommendation: We recommend the University review the internal controls over the administration of federal funds to ensure documentation is created and retained in accordance with federal and pass-through requirements.
Program: Child and Adult Care Food Program Assistance Listing Number: 10.558 Federal Agency: U.S. Department of Agriculture Pass-Through Grantor: New York State Department of Health Award Identification: 03256, 03257 Year 2022 Criteria: Eligibility; Subrecipient Monitoring – Entities should retain all financial records, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334. Condition: During the course of our audit procedures performed on eligibility and subrecipient monitoring, there were instances where participant records could not be located for both children and providers. Questioned costs: Unknown. Context: We tested a sample of 49 of 225 children, and 11 of 43 providers for eligibility. No records for the year could be provided for 1 of the selections for compliance, and no evidence of review and approval could be provided for 6 of the records. Additionally, we tested 11 out of 43 providers for subrecipient monitoring. No records could be provided for one of the selections. The sample was not and was not intended to be statistically valid. Effect: We were unable to verify compliance with eligibility and subrecipient monitoring requirements. Cause: The Settlement did not have internal controls in place related to eligibility and subrecipient monitoring. Repeat finding: This is a repeat finding (2021-009). Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation. Views of responsible officials and planned corrective actions: The Settlement agrees with the finding. Fiscal and program staff will update CACFP Policies and Procedures to ensure that all CACFP records are retained for a minimum of three years. CACFP eligibility will be clearly documented and retained for three years by program staff. Fiscal and program staff will update CACFP Policies and Procedures to reflect subrecipient eligibility and related paperwork. Staff will be trained on completing and maintaining CACFP enrollment and eligibility paperwork via CACFP online workshops. Managers will complete management KidKare training to optimize electronic recordkeeping of CACFP documentation. The Compliance Director will complete an unannounced monitoring review of enrollment paperwork quarterly. Policies and Procedures will be edited to reflect rules and regulations for enrollment and eligibility paperwork. Implementation began October 2023.
Program: Child and Adult Care Food Program Assistance Listing Number: 10.558 Federal Agency: U.S. Department of Agriculture Pass-Through Grantor: New York State Department of Health Award Identification: 03256, 03257 Year 2022 Criteria: Eligibility; Subrecipient Monitoring – Entities should retain all financial records, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334. Condition: During the course of our audit procedures performed on eligibility and subrecipient monitoring, there were instances where participant records could not be located for both children and providers. Questioned costs: Unknown. Context: We tested a sample of 49 of 225 children, and 11 of 43 providers for eligibility. No records for the year could be provided for 1 of the selections for compliance, and no evidence of review and approval could be provided for 6 of the records. Additionally, we tested 11 out of 43 providers for subrecipient monitoring. No records could be provided for one of the selections. The sample was not and was not intended to be statistically valid. Effect: We were unable to verify compliance with eligibility and subrecipient monitoring requirements. Cause: The Settlement did not have internal controls in place related to eligibility and subrecipient monitoring. Repeat finding: This is a repeat finding (2021-009). Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation. Views of responsible officials and planned corrective actions: The Settlement agrees with the finding. Fiscal and program staff will update CACFP Policies and Procedures to ensure that all CACFP records are retained for a minimum of three years. CACFP eligibility will be clearly documented and retained for three years by program staff. Fiscal and program staff will update CACFP Policies and Procedures to reflect subrecipient eligibility and related paperwork. Staff will be trained on completing and maintaining CACFP enrollment and eligibility paperwork via CACFP online workshops. Managers will complete management KidKare training to optimize electronic recordkeeping of CACFP documentation. The Compliance Director will complete an unannounced monitoring review of enrollment paperwork quarterly. Policies and Procedures will be edited to reflect rules and regulations for enrollment and eligibility paperwork. Implementation began October 2023.
Program: Head Start Cluster Assistance Listing Number: 93.600 Federal Agency: U.S. Department of Labor Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144 Criteria: Reporting – The organization should retain all financial records, reports, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334. Condition: During the course of our audit procedures performed on reporting, it was noted that the annual report on real property required to be filed, could not be located. In addition, for the eight financial reports that were filed, the supporting information for the amounts included could not be located. Questioned costs: None Context: We requested all reports required to be filed for the expenditures made during the period, which included both financial and special reports, as well as the underlying documentation to support the amounts included in the reports. The organization could not locate the annual report on real property. Additionally, supporting documentation could not be located for the eight financial reports that were filed. Effect: Reports not filed, reviewed, or signed may cause inaccurate information at the award agency and could cause delays in payments or impact future funding. Cause: The Settlement did not have adequate controls and procedures in place to identify reporting requirements and ensure reports were filed timely. Repeat finding: This is a repeat finding (2021-007) Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation. In addition, management should implement policies and procedures to ensure required reports are completed and filed by their respective due dates as required by the grant agreement and the Uniform Guidance. Views of responsible officials and planned corrective actions: The Settlement agrees with the finding. The Assistant Controller prepares the form SF-425 reports and the Controller reviews and approves them for submission. These forms and supporting documentation are saved and retained in SharePoint. SF-425 due dates reminders are posted in preparer’s calendar and adherence to the due dates is monitored by the Controller. Implementation began July 2022.
Program: Head Start Cluster Assistance Listing Number: 93.600 Federal Agency: U.S. Department of Labor Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144 Criteria: Reporting – The organization should retain all financial records, reports, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334. Condition: During the course of our audit procedures performed on reporting, it was noted that the annual report on real property required to be filed, could not be located. In addition, for the eight financial reports that were filed, the supporting information for the amounts included could not be located. Questioned costs: None Context: We requested all reports required to be filed for the expenditures made during the period, which included both financial and special reports, as well as the underlying documentation to support the amounts included in the reports. The organization could not locate the annual report on real property. Additionally, supporting documentation could not be located for the eight financial reports that were filed. Effect: Reports not filed, reviewed, or signed may cause inaccurate information at the award agency and could cause delays in payments or impact future funding. Cause: The Settlement did not have adequate controls and procedures in place to identify reporting requirements and ensure reports were filed timely. Repeat finding: This is a repeat finding (2021-007) Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation. In addition, management should implement policies and procedures to ensure required reports are completed and filed by their respective due dates as required by the grant agreement and the Uniform Guidance. Views of responsible officials and planned corrective actions: The Settlement agrees with the finding. The Assistant Controller prepares the form SF-425 reports and the Controller reviews and approves them for submission. These forms and supporting documentation are saved and retained in SharePoint. SF-425 due dates reminders are posted in preparer’s calendar and adherence to the due dates is monitored by the Controller. Implementation began July 2022.
Program: Head Start Cluster Assistance Listing Number: 93.600 Federal Agency: U.S. Department of Labor Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144 Criteria: Reporting – The organization should retain all financial records, reports, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334. Condition: During the course of our audit procedures performed on reporting, it was noted that the annual report on real property required to be filed, could not be located. In addition, for the eight financial reports that were filed, the supporting information for the amounts included could not be located. Questioned costs: None Context: We requested all reports required to be filed for the expenditures made during the period, which included both financial and special reports, as well as the underlying documentation to support the amounts included in the reports. The organization could not locate the annual report on real property. Additionally, supporting documentation could not be located for the eight financial reports that were filed. Effect: Reports not filed, reviewed, or signed may cause inaccurate information at the award agency and could cause delays in payments or impact future funding. Cause: The Settlement did not have adequate controls and procedures in place to identify reporting requirements and ensure reports were filed timely. Repeat finding: This is a repeat finding (2021-007) Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation. In addition, management should implement policies and procedures to ensure required reports are completed and filed by their respective due dates as required by the grant agreement and the Uniform Guidance. Views of responsible officials and planned corrective actions: The Settlement agrees with the finding. The Assistant Controller prepares the form SF-425 reports and the Controller reviews and approves them for submission. These forms and supporting documentation are saved and retained in SharePoint. SF-425 due dates reminders are posted in preparer’s calendar and adherence to the due dates is monitored by the Controller. Implementation began July 2022.
Program: Head Start Cluster Assistance Listing Number: 93.600 Federal Agency: U.S. Department of Labor Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144 Criteria: Reporting – The organization should retain all financial records, reports, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334. Condition: During the course of our audit procedures performed on reporting, it was noted that the annual report on real property required to be filed, could not be located. In addition, for the eight financial reports that were filed, the supporting information for the amounts included could not be located. Questioned costs: None Context: We requested all reports required to be filed for the expenditures made during the period, which included both financial and special reports, as well as the underlying documentation to support the amounts included in the reports. The organization could not locate the annual report on real property. Additionally, supporting documentation could not be located for the eight financial reports that were filed. Effect: Reports not filed, reviewed, or signed may cause inaccurate information at the award agency and could cause delays in payments or impact future funding. Cause: The Settlement did not have adequate controls and procedures in place to identify reporting requirements and ensure reports were filed timely. Repeat finding: This is a repeat finding (2021-007) Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation. In addition, management should implement policies and procedures to ensure required reports are completed and filed by their respective due dates as required by the grant agreement and the Uniform Guidance. Views of responsible officials and planned corrective actions: The Settlement agrees with the finding. The Assistant Controller prepares the form SF-425 reports and the Controller reviews and approves them for submission. These forms and supporting documentation are saved and retained in SharePoint. SF-425 due dates reminders are posted in preparer’s calendar and adherence to the due dates is monitored by the Controller. Implementation began July 2022.
Condition: Finding Costs Charged to the Federal Program Not Supported by Sufficient Documentation (Material Weakness – Allowable Costs) Information on the Federal Programs: Child Nutrition Cluster: 10.553, 10.555, 10.559 Questioned Costs $33,572 During testing over allowable costs, it was noted that 20 out of 40 transactions of costs charged to the federal program were not supported by documentation as required by the Uniform Guidance (2 CFR 200, Subparts D Post Federal Award Requirements and E Cost Principles). Criteria: Uniform Guidance 2 CFR 200, Subparts D Post Federal Award Requirements and E Cost Principles. Per 2 CFR §200.334 Retention Requirements for Records, supporting documentation must be retained for a period of three years. Cause: Documentation was not maintained for costs charged to the federal program to support that expenditures were allowable per 2 CFR 200 Subpart E Cost Principles. Effect: Potential effects include unallowed costs being charged to federal programs resulting in possible reduction in funding. Isolated Instance or Systemic Problem: We consider this to be a systemic problem. Repeat of Prior Year Finding: No. Recommendation: We recommend that the School Department implement a system of controls including policies and procedures on maintaining documentation for costs charged to federal award programs where supporting documentation is accessible by management or other responsible individuals.
Condition: Finding Costs Charged to the Federal Program Not Supported by Sufficient Documentation (Material Weakness – Allowable Costs) Information on the Federal Programs: Child Nutrition Cluster: 10.553, 10.555, 10.559 Questioned Costs $33,572 During testing over allowable costs, it was noted that 20 out of 40 transactions of costs charged to the federal program were not supported by documentation as required by the Uniform Guidance (2 CFR 200, Subparts D Post Federal Award Requirements and E Cost Principles). Criteria: Uniform Guidance 2 CFR 200, Subparts D Post Federal Award Requirements and E Cost Principles. Per 2 CFR §200.334 Retention Requirements for Records, supporting documentation must be retained for a period of three years. Cause: Documentation was not maintained for costs charged to the federal program to support that expenditures were allowable per 2 CFR 200 Subpart E Cost Principles. Effect: Potential effects include unallowed costs being charged to federal programs resulting in possible reduction in funding. Isolated Instance or Systemic Problem: We consider this to be a systemic problem. Repeat of Prior Year Finding: No. Recommendation: We recommend that the School Department implement a system of controls including policies and procedures on maintaining documentation for costs charged to federal award programs where supporting documentation is accessible by management or other responsible individuals.
Condition: Finding Costs Charged to the Federal Program Not Supported by Sufficient Documentation (Material Weakness – Allowable Costs) Information on the Federal Programs: Child Nutrition Cluster: 10.553, 10.555, 10.559 Questioned Costs $33,572 During testing over allowable costs, it was noted that 20 out of 40 transactions of costs charged to the federal program were not supported by documentation as required by the Uniform Guidance (2 CFR 200, Subparts D Post Federal Award Requirements and E Cost Principles). Criteria: Uniform Guidance 2 CFR 200, Subparts D Post Federal Award Requirements and E Cost Principles. Per 2 CFR §200.334 Retention Requirements for Records, supporting documentation must be retained for a period of three years. Cause: Documentation was not maintained for costs charged to the federal program to support that expenditures were allowable per 2 CFR 200 Subpart E Cost Principles. Effect: Potential effects include unallowed costs being charged to federal programs resulting in possible reduction in funding. Isolated Instance or Systemic Problem: We consider this to be a systemic problem. Repeat of Prior Year Finding: No. Recommendation: We recommend that the School Department implement a system of controls including policies and procedures on maintaining documentation for costs charged to federal award programs where supporting documentation is accessible by management or other responsible individuals.
FINDING 2022-002Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS17SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)One of five annual reports required to be completed during the audit period contained materialerrors. The Elementary and Secondary School Emergency Relief (ESSER I), Year 1 annual data reportoverstated total expenditures made between March 13, 2020, and September, 30, 2020, by $130,918. Inaddition, documentation provided for the number of full-time employee positions did not support theamounts reported.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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 ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS18SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS17SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)One of five annual reports required to be completed during the audit period contained materialerrors. The Elementary and Secondary School Emergency Relief (ESSER I), Year 1 annual data reportoverstated total expenditures made between March 13, 2020, and September, 30, 2020, by $130,918. Inaddition, documentation provided for the number of full-time employee positions did not support theamounts reported.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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 ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS18SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-010Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionINDIANA STATE BOARD OF ACCOUNTS33BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed or implemented at the School Corporation toensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reportstested, the Reports were not supported by the unit's records. The financial information provided did notagree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports.Additionally, seven of seven key line items selected for testing could not be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in?? 200.328 and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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 ofa subrecipient. . . ."INDIANA STATE BOARD OF ACCOUNTS34BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to design and implement an effective internal control system enabled noncompliance togo undetected with the Reporting compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.INDIANA STATE BOARD OF ACCOUNTS35
FINDING 2022-010Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionINDIANA STATE BOARD OF ACCOUNTS33BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed or implemented at the School Corporation toensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reportstested, the Reports were not supported by the unit's records. The financial information provided did notagree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports.Additionally, seven of seven key line items selected for testing could not be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in?? 200.328 and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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 ofa subrecipient. . . ."INDIANA STATE BOARD OF ACCOUNTS34BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to design and implement an effective internal control system enabled noncompliance togo undetected with the Reporting compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.INDIANA STATE BOARD OF ACCOUNTS35
FINDING 2022-010Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionINDIANA STATE BOARD OF ACCOUNTS33BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed or implemented at the School Corporation toensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reportstested, the Reports were not supported by the unit's records. The financial information provided did notagree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports.Additionally, seven of seven key line items selected for testing could not be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in?? 200.328 and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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 ofa subrecipient. . . ."INDIANA STATE BOARD OF ACCOUNTS34BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to design and implement an effective internal control system enabled noncompliance togo undetected with the Reporting compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.INDIANA STATE BOARD OF ACCOUNTS35
FINDING 2022-010Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionINDIANA STATE BOARD OF ACCOUNTS33BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed or implemented at the School Corporation toensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reportstested, the Reports were not supported by the unit's records. The financial information provided did notagree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports.Additionally, seven of seven key line items selected for testing could not be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in?? 200.328 and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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 ofa subrecipient. . . ."INDIANA STATE BOARD OF ACCOUNTS34BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to design and implement an effective internal control system enabled noncompliance togo undetected with the Reporting compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.INDIANA STATE BOARD OF ACCOUNTS35
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersINDIANA STATE BOARD OF ACCOUNTS22MONROE COUNTY COMMUNITY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with the requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation filed the four required Elementary and Secondary School EmergencyRelief (ESSER) annual data reports. However, the ESSER I, Year 1 and ESSER I, Year 2 reports werenot supported by the School Corporation's records. For each of the reports, two key line items wereselected for verification, none of the line items tested were supported by the School Corporation's records.For the ESSER I, Year 2 report the data included expenditures for two months beyond the reporting period.The lack of internal controls and noncompliance were applicable to the ESSER I grant during theaudit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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 ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."INDIANA STATE BOARD OF ACCOUNTS23MONROE COUNTY COMMUNITY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not designed, nor implemented a system of internal controls that would haveensured compliance or that supporting documentation would have been maintained and available for auditrelated to the Reporting compliance requirement.EffectThe failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Noncompliancewith the grant agreement and the Reporting compliance requirement could result in the loss of future federalfunds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grantagreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersINDIANA STATE BOARD OF ACCOUNTS22MONROE COUNTY COMMUNITY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with the requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation filed the four required Elementary and Secondary School EmergencyRelief (ESSER) annual data reports. However, the ESSER I, Year 1 and ESSER I, Year 2 reports werenot supported by the School Corporation's records. For each of the reports, two key line items wereselected for verification, none of the line items tested were supported by the School Corporation's records.For the ESSER I, Year 2 report the data included expenditures for two months beyond the reporting period.The lack of internal controls and noncompliance were applicable to the ESSER I grant during theaudit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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 ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."INDIANA STATE BOARD OF ACCOUNTS23MONROE COUNTY COMMUNITY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not designed, nor implemented a system of internal controls that would haveensured compliance or that supporting documentation would have been maintained and available for auditrelated to the Reporting compliance requirement.EffectThe failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Noncompliancewith the grant agreement and the Reporting compliance requirement could result in the loss of future federalfunds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grantagreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D20013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not designed, nor implemented, at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. The Reports were prepared byone employee without an oversite or review process in place to prevent, or detect and correct, errors.Additionally, one of the four Reports tested was not supported by the School Corporation's records.The financial information provided did not agree to all the data submitted in the Report; therefore, we couldnot determine the accuracy of the Report. Additionally, two of six key line items selected for testing couldnot be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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.. . ."34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Reporting compliance requirement could resultin the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D20013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not designed, nor implemented, at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. The Reports were prepared byone employee without an oversite or review process in place to prevent, or detect and correct, errors.Additionally, one of the four Reports tested was not supported by the School Corporation's records.The financial information provided did not agree to all the data submitted in the Report; therefore, we couldnot determine the accuracy of the Report. Additionally, two of six key line items selected for testing couldnot be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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.. . ."34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Reporting compliance requirement could resultin the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D20013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not designed, nor implemented, at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. The Reports were prepared byone employee without an oversite or review process in place to prevent, or detect and correct, errors.Additionally, one of the four Reports tested was not supported by the School Corporation's records.The financial information provided did not agree to all the data submitted in the Report; therefore, we couldnot determine the accuracy of the Report. Additionally, two of six key line items selected for testing couldnot be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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.. . ."34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Reporting compliance requirement could resultin the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D20013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not designed, nor implemented, at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. The Reports were prepared byone employee without an oversite or review process in place to prevent, or detect and correct, errors.Additionally, one of the four Reports tested was not supported by the School Corporation's records.The financial information provided did not agree to all the data submitted in the Report; therefore, we couldnot determine the accuracy of the Report. Additionally, two of six key line items selected for testing couldnot be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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.. . ."34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Reporting compliance requirement could resultin the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Department of Health and Human Services Temporary Assistance for Needy Families (TANF), Federal Assistance Listing # 93.558 Pass Through Virginia Department of Social Services, Pass Through Entity Identifying Number BEN-21-054 Type of Finding: Significant Deficiency in Internal Control over Compliance with Federal Awards Criteria: The Organization should have effective internal controls in place over review of intake forms, per 2 CFR 200.303 and 2 CFR 200.334. Condition: During our audit, it was noted that there was not an effective review of intake forms. Context: During testing, 6 of 60 intake forms tested to not contain appropriate signatures by individuals or management noting approval. The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: N/A Cause/Effect: Internal control processes over intake forms were not operating effectively from July 2021 through June 2022. Identification of Repeat Finding: N/A Recommendation: We recommend that Cornerstones implements a review process to ensure that intake forms are complete and accurate as possess all appropriate signatures. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Department of Health and Human Services Temporary Assistance for Needy Families (TANF), Federal Assistance Listing # 93.558 Pass Through Virginia Department of Social Services, Pass Through Entity Identifying Number BEN-21-054 Type of Finding: Significant Deficiency in Internal Control over Compliance with Federal Awards Criteria: The Organization should have processes and procedures in place to keep and maintain client records, per 2 CFR 200.303 and 2 CFR 200.334. Condition: During our audit, we noted that the Organization was unable to find supporting records for individuals that received services as part of a federal program, leading to noncompliance with the program. Context: During testing, 4 of 60 individuals tested did not have the appropriate records. The sample was not intended to be, and was not, a statistically valid sample. Cause/Effect: Internal control processes over proper maintenance of clients’ records were not operating effectively, causing eligibility documentation to not be located. Questioned Costs: N/A Identification of Repeat Finding: N/A Recommendation: We recommend procedures are implemented to ensure proper maintenance of client records. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Department of Health and Human Services Temporary Assistance for Needy Families (TANF), Federal Assistance Listing # 93.558 Pass Through Virginia Department of Social Services, Pass Through Entity Identifying Number BEN-21-054 Type of Finding: Significant Deficiency in Internal Control over Compliance with Federal Awards Criteria: The Organization should have effective internal controls in place over review of intake forms, per 2 CFR 200.303 and 2 CFR 200.334. Condition: During our audit, it was noted that there was not an effective review of intake forms. Context: During testing, 6 of 60 intake forms tested to not contain appropriate signatures by individuals or management noting approval. The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: N/A Cause/Effect: Internal control processes over intake forms were not operating effectively from July 2021 through June 2022. Identification of Repeat Finding: N/A Recommendation: We recommend that Cornerstones implements a review process to ensure that intake forms are complete and accurate as possess all appropriate signatures. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Department of Health and Human Services Temporary Assistance for Needy Families (TANF), Federal Assistance Listing # 93.558 Pass Through Virginia Department of Social Services, Pass Through Entity Identifying Number BEN-21-054 Type of Finding: Significant Deficiency in Internal Control over Compliance with Federal Awards Criteria: The Organization should have processes and procedures in place to keep and maintain client records, per 2 CFR 200.303 and 2 CFR 200.334. Condition: During our audit, we noted that the Organization was unable to find supporting records for individuals that received services as part of a federal program, leading to noncompliance with the program. Context: During testing, 4 of 60 individuals tested did not have the appropriate records. The sample was not intended to be, and was not, a statistically valid sample. Cause/Effect: Internal control processes over proper maintenance of clients’ records were not operating effectively, causing eligibility documentation to not be located. Questioned Costs: N/A Identification of Repeat Finding: N/A Recommendation: We recommend procedures are implemented to ensure proper maintenance of client records. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Criteria: The Organization is required to establish and maintain effective internal controls over financial documentation to ensure compliance with federal regulations, as outlined in 2 CFR 200.303 and 2 CFR 200.334 of the Uniform Guidance. These controls are crucial for the accurate management and reporting of federal funds. Statement of Condition: During our audit, it was identified that the Organization could not locate invoices or check stubs for five out of sixty items tested for non-payroll expenses within a major federal program. Cause: The existing internal control processes related to the organization and retrieval of financial documentation appear to be insufficient, a situation that was exacerbated by staffing shortages during the period under audit. Addressing these challenges through enhanced processes and adequate staffing could improve the Organization's ability to provide timely and complete documentation. Effect or Potential Effect: The inability to produce essential financial documentation may lead to compliance challenges with federal funding requirements. Additionally, this increases the risk of questioned costs, which could have financial implications for the Organization if not rectified. Recommendation: It is recommended that the Organization implement enhanced procedures for the systematic maintenance and retrieval of all financial records related to expenditures. This should include staff training on these protocols to ensure compliance and improve overall internal controls. Management’s Response: Management agrees with this finding. Please refer to the Corrective Action Plan for further details.
Block Grants for Prevention and Treatment of Substance Abuse ALN No. 93.959 U.S. Department of Health and Human Services Opioid STR ALN No. 93.788 U.S. Department of Health and Human Services Criteria or Specific Requirement – Activities Allowed and Unallowed and Cost Principles – 2 CFR Part 200, Subpart E, and Period of Performance – 2 CFR sections 200.308, 200.309, and 200.403(h) Condition – A sample of 80 expenditures were selected from each of the following populations: • ALN No. 93.959 – 1,839 items totaling $1,243,944 • ALN No. 93.788 – 1,502 items totaling $2,285,983 The samples were not, and are not intended to be, statistically valid. Of the 80 expenditures tested from each grant program, the following were determined to lack appropriate supporting documentation to support being charged to grant program: • ALN No. 93.959 - 51 items totaling $26,145, including projected errors over the total population totaling $348,063 • ALN No. 93.788 - 6 items totaling $18,183, including projected errors over the total population totaling $165,074 The Organization did not have adequate supporting documentation demonstrating actual time and effort reporting and lacked evidence of supporting invoices. Cause – The Organization charged budgeted percentages to the grant programs without a system in place to monitor and track that actual time and effort was consistent with budgeted percentages. In addition, the Organization charged expenditures to the grant programs without evidence of supporting invoices. Effect or potential effect – Costs charged to the grant programs could have varied from actual time and effort. In addition, costs charged to the grant could not be supported by actual invoices. Questioned costs – • ALN No. 93.959 - $26,145 • ALN No. 93.788 - $18,183 Context – The Organization did not have a reasonable methodology of allocating costs to these grant programs and did not maintain proper supporting invoices. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – Management should implement policies and procedures that strengthen internal control over compliance in relation to activities allowed and cost principles. The policy and procedure should be designed to ensure that a reasonable allocation methodology is implemented and followed or that time and effort is certified by the employee on a regular basis. In addition, management should implement a document retention policy consistent with 2 CFR 200.334.
Block Grants for Prevention and Treatment of Substance Abuse ALN No. 93.959 U.S. Department of Health and Human Services Opioid STR ALN No. 93.788 U.S. Department of Health and Human Services Criteria or Specific Requirement – Activities Allowed and Unallowed and Cost Principles – 2 CFR Part 200, Subpart E, and Period of Performance – 2 CFR sections 200.308, 200.309, and 200.403(h) Condition – A sample of 80 expenditures were selected from each of the following populations: • ALN No. 93.959 – 1,839 items totaling $1,243,944 • ALN No. 93.788 – 1,502 items totaling $2,285,983 The samples were not, and are not intended to be, statistically valid. Of the 80 expenditures tested from each grant program, the following were determined to lack appropriate supporting documentation to support being charged to grant program: • ALN No. 93.959 - 51 items totaling $26,145, including projected errors over the total population totaling $348,063 • ALN No. 93.788 - 6 items totaling $18,183, including projected errors over the total population totaling $165,074 The Organization did not have adequate supporting documentation demonstrating actual time and effort reporting and lacked evidence of supporting invoices. Cause – The Organization charged budgeted percentages to the grant programs without a system in place to monitor and track that actual time and effort was consistent with budgeted percentages. In addition, the Organization charged expenditures to the grant programs without evidence of supporting invoices. Effect or potential effect – Costs charged to the grant programs could have varied from actual time and effort. In addition, costs charged to the grant could not be supported by actual invoices. Questioned costs – • ALN No. 93.959 - $26,145 • ALN No. 93.788 - $18,183 Context – The Organization did not have a reasonable methodology of allocating costs to these grant programs and did not maintain proper supporting invoices. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – Management should implement policies and procedures that strengthen internal control over compliance in relation to activities allowed and cost principles. The policy and procedure should be designed to ensure that a reasonable allocation methodology is implemented and followed or that time and effort is certified by the employee on a regular basis. In addition, management should implement a document retention policy consistent with 2 CFR 200.334.
2022-002 Improve Internal Controls and Documentation over Allowable Costs and Eligibility Determinations Federal Program Information Federal Agency: Department of the Treasury Award Name: COVID-19 Emergency Rental Assistance Program Assistance Listing Number: 21.023 Award Year: 2022 Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement Per 2 CFR 200.303, the County is required to establish and maintain effective internal controls over federal programs to provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of the award. Additionally, 2 CFR 200.334 requires the retention of records and supporting documentation to demonstrate eligibility determinations and allowability of expenditures under the program. Condition and Context During our audit, we tested a sample of 40 selections for allowable costs, as well as a sample of 40 for individual eligibility determinations under the program in which 35 selections were leveraged between the two tests. For 8 of the items selected for testing under allowable cost compliance and eligibility requirements, the County was unable to provide some or all of the required supporting documentation to demonstrate that individuals met the program’s eligibility requirements and that costs were allowable. The documentation was retained in an online portal to which the County no longer had access at the time of our audit procedures. Cause The County did not establish sufficient procedures or controls to ensure ongoing access to required supporting documentation maintained in the external portal used for program administration. Effect or Potential Effect Due to the weakness in internal controls noted above, the County could not demonstrate compliance with eligibility and allowable cost requirements for the sampled transactions. This also constitutes noncompliance with record retention requirements and impairs the ability for sufficient procedures to be performed over the program. Questioned Costs Due to the condition noted above, we were unable to determine if the costs charged to the applicable grant are allowable. Recommendation The County should implement policies and procedures to ensure required documentation for the program is retained in a manner that ensures continued access, even if administration platforms change or external portals are no longer accessible. The County should also periodically verify that it retains all necessary support for program transactions as required under federal regulations. Views of Responsible Official and Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
U.S. Department of Housing and Urban Development Federal Financial Assistance Listing # 14.157 Supportive Housing for the Elderly (Section 202) Project Rental Assistance Contract Number: ND99S091001 Project Number: 094-EE008-NP-WAH Activities Allowed/Unallowed and Allowable Costs/Cost Principles/Eligibility/Special Tests and Provisions Material Weakness in Internal Control over Compliance Criteria – CFR Section 200.334 indicates that financial records, supporting documentation, and all other entity records pertinent to federal awards must be retained for a period of three years. Condition – The Organization does not have an internal control system designed to provide for the appropriate retention of documentation supporting the transactions of the Organization and eligibility determinations of tenants at the project. As a result, through the transition of management, supporting documentation for expense transactions and tenant eligibility were destroyed and not able to be recreated. Cause – Due to a lack of control policies and proper enforcement, documents were inadvertently destroyed. Effect – Inadequate controls over document retention for the Organization could result in inaccurate transactions being recorded within the Organization’s financial statements or ineligible tenants occupying the units, which could result in non-compliance. Questioned Costs – None Reported. Context/Sampling – Not Applicable. Repeat Finding from Prior Year(s) – No. Recommendation – It is the responsibility of management and those charged with governance to develop and enforce proper controls and monitoring over document retention policies. Views of Responsible Officials – Management agrees with the finding.
U.S. Department of Housing and Urban Development Federal Financial Assistance Listing # 14.157 Supportive Housing for the Elderly (Section 202) Project Rental Assistance Contract Number: ND99S091001 Project Number: 094-EE008-NP-WAH Activities Allowed/Unallowed and Allowable Costs/Cost Principles/Eligibility/Special Tests and Provisions Material Weakness in Internal Control over Compliance Criteria – CFR Section 200.334 indicates that financial records, supporting documentation, and all other entity records pertinent to federal awards must be retained for a period of three years. Condition – The Organization does not have an internal control system designed to provide for the appropriate retention of documentation supporting the transactions of the Organization and eligibility determinations of tenants at the project. As a result, through the transition of management, supporting documentation for expense transactions and tenant eligibility were destroyed and not able to be recreated. Cause – Due to a lack of control policies and proper enforcement, documents were inadvertently destroyed. Effect – Inadequate controls over document retention for the Organization could result in inaccurate transactions being recorded within the Organization’s financial statements or ineligible tenants occupying the units, which could result in non-compliance. Questioned Costs – None Reported. Context/Sampling – Not Applicable. Repeat Finding from Prior Year(s) – No. Recommendation – It is the responsibility of management and those charged with governance to develop and enforce proper controls and monitoring over document retention policies. Views of Responsible Officials – Management agrees with the finding.
2021-009 Inability to Test Compliance (Material Weakness) Federal Agency: Department of Education Pass-through Agency: New Hampshire Department of Education Cluster/Program: Title I Assistance Listing Number: 84.010 Passed-through Identification: 20210848 Compliance Requirements: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.334, recipients of federal funds must retain financial and programmatic records, supporting documents, statistical records, and all other records pertinent to a federal award for a period of three years from the date of submission of the final expenditure report. Additionally, per 2 CFR 200.303, recipients must establish and maintain effective internal control over federal awards to ensure compliance with federal statutes, regulations, and the terms and conditions of the award. Condition: The School District informed the engagement team that it was unable to locate all required documentation necessary to support expenditures and compliance with federal program requirements. This affected our ability to complete the required testing over the major program. Cause: The School District does not have a consistent or centralized process for retaining and organizing documentation related to federal program expenditures and compliance requirements. Staff turnover and lack of clear documentation procedures contributed to the unavailability of records. Effect: Due to the absence of required supporting documentation, we were unable to obtain sufficient appropriate audit evidence to support compliance with the federal requirements for the affected programs. As a result, we were unable to determine whether certain transactions were allowable and in compliance with the applicable grant requirements. This represents a material noncompliance with federal regulations and may result in questioned costs or other remedial actions by the granting agency. Questioned Costs: $989,166. This amount represents the total presented on the Schedule of Expenditures of Federal Awards. The entire amount is in question because no testing could be performed as required documentation was not retained by the School District. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement stronger internal controls over document retention, including centralized digital storage systems, regular staff training on federal documentation requirements, and written procedures outlining retention responsibilities. These procedures should ensure that all required documentation is maintained and readily accessible for audit and monitoring purposes. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2021-010 Inability to Test Compliance (Material Weakness) Federal Agency: Department of Education Pass-through Agency: New Hampshire Department of Education Cluster/Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D Passed-through Identification: 20204986 & 20211886 Compliance Requirements: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.334, recipients of federal funds must retain financial and programmatic records, supporting documents, statistical records, and all other records pertinent to a federal award for a period of three years from the date of submission of the final expenditure report. Additionally, per 2 CFR 200.303, recipients must establish and maintain effective internal control over federal awards to ensure compliance with federal statutes, regulations, and the terms and conditions of the award. Condition: The School District informed the engagement team that it was unable to locate all required documentation necessary to support expenditures and compliance with federal program requirements. This affected our ability to complete the required testing over the major program. Cause: The School District does not have a consistent or centralized process for retaining and organizing documentation related to federal program expenditures and compliance requirements. Staff turnover and lack of clear documentation procedures contributed to the unavailability of records. Effect: Due to the absence of required supporting documentation, we were unable to obtain sufficient appropriate audit evidence to support compliance with the federal requirements for the affected programs. As a result, we were unable to determine whether certain transactions were allowable and in compliance with the applicable grant requirements. This represents a material noncompliance with federal regulations and may result in questioned costs or other remedial actions by the granting agency. Questioned Costs: $505,347. This amount represents the total presented on the Schedule of Expenditures of Federal Awards. The entire amount is in question because no testing could be performed as required documentation was not retained by the School District. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement stronger internal controls over document retention, including centralized digital storage systems, regular staff training on federal documentation requirements, and written procedures outlining retention responsibilities. These procedures should ensure that all required documentation is maintained and readily accessible for audit and monitoring purposes. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2021-010 Inability to Test Compliance (Material Weakness) Federal Agency: Department of Education Pass-through Agency: New Hampshire Department of Education Cluster/Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D Passed-through Identification: 20204986 & 20211886 Compliance Requirements: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.334, recipients of federal funds must retain financial and programmatic records, supporting documents, statistical records, and all other records pertinent to a federal award for a period of three years from the date of submission of the final expenditure report. Additionally, per 2 CFR 200.303, recipients must establish and maintain effective internal control over federal awards to ensure compliance with federal statutes, regulations, and the terms and conditions of the award. Condition: The School District informed the engagement team that it was unable to locate all required documentation necessary to support expenditures and compliance with federal program requirements. This affected our ability to complete the required testing over the major program. Cause: The School District does not have a consistent or centralized process for retaining and organizing documentation related to federal program expenditures and compliance requirements. Staff turnover and lack of clear documentation procedures contributed to the unavailability of records. Effect: Due to the absence of required supporting documentation, we were unable to obtain sufficient appropriate audit evidence to support compliance with the federal requirements for the affected programs. As a result, we were unable to determine whether certain transactions were allowable and in compliance with the applicable grant requirements. This represents a material noncompliance with federal regulations and may result in questioned costs or other remedial actions by the granting agency. Questioned Costs: $505,347. This amount represents the total presented on the Schedule of Expenditures of Federal Awards. The entire amount is in question because no testing could be performed as required documentation was not retained by the School District. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement stronger internal controls over document retention, including centralized digital storage systems, regular staff training on federal documentation requirements, and written procedures outlining retention responsibilities. These procedures should ensure that all required documentation is maintained and readily accessible for audit and monitoring purposes. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
U.S. Department of Housing and Urban Development Federal Financial Assistance Listing # 14.157 Supportive Housing for the Elderly (Section 202) Project Rental Assistance Contract Number: ND99S091001 Project Number: 094-EE008-NP-WAH Activities Allowed/Unallowed and Allowable Costs/Cost Principles/Eligibility/Special Tests and Provisions Material Weakness in Internal Control over Compliance Criteria – CFR Section 200.334 indicates that financial records, supporting documentation, and all other entity records pertinent to federal awards must be retained for a period of three years. Condition – The Organization does not have an internal control system designed to provide for the appropriate retention of documentation supporting the transactions of the Organization and eligibility determinations of tenants at the project. As a result, through the transition of management, supporting documentation for expense transactions and tenant eligibility were destroyed and not able to be recreated. Cause – Due to a lack of control policies and proper enforcement, documents were inadvertently destroyed. Effect – Inadequate controls over document retention for the Organization could result in inaccurate transactions being recorded within the Organization’s financial statements or ineligible tenants occupying the units, which could result in non-compliance. Questioned Costs – None Reported. Context/Sampling – Not Applicable. Repeat Finding from Prior Year(s) – No. Recommendation – It is the responsibility of management and those charged with governance to develop and enforce proper controls and monitoring over document retention policies. Views of Responsible Officials – Management agrees with the finding.
U.S. Department of Housing and Urban Development Federal Financial Assistance Listing # 14.157 Supportive Housing for the Elderly (Section 202) Project Rental Assistance Contract Number: ND99S091001 Project Number: 094-EE008-NP-WAH Activities Allowed/Unallowed and Allowable Costs/Cost Principles/Eligibility/Special Tests and Provisions Material Weakness in Internal Control over Compliance Criteria – CFR Section 200.334 indicates that financial records, supporting documentation, and all other entity records pertinent to federal awards must be retained for a period of three years. Condition – The Organization does not have an internal control system designed to provide for the appropriate retention of documentation supporting the transactions of the Organization and eligibility determinations of tenants at the project. As a result, through the transition of management, supporting documentation for expense transactions and tenant eligibility were destroyed and not able to be recreated. Cause – Due to a lack of control policies and proper enforcement, documents were inadvertently destroyed. Effect – Inadequate controls over document retention for the Organization could result in inaccurate transactions being recorded within the Organization’s financial statements or ineligible tenants occupying the units, which could result in non-compliance. Questioned Costs – None Reported. Context/Sampling – Not Applicable. Repeat Finding from Prior Year(s) – No. Recommendation – It is the responsibility of management and those charged with governance to develop and enforce proper controls and monitoring over document retention policies. Views of Responsible Officials – Management agrees with the finding.
2021-009 Inability to Test Compliance (Material Weakness) Federal Agency: Department of Education Pass-through Agency: New Hampshire Department of Education Cluster/Program: Title I Assistance Listing Number: 84.010 Passed-through Identification: 20210848 Compliance Requirements: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.334, recipients of federal funds must retain financial and programmatic records, supporting documents, statistical records, and all other records pertinent to a federal award for a period of three years from the date of submission of the final expenditure report. Additionally, per 2 CFR 200.303, recipients must establish and maintain effective internal control over federal awards to ensure compliance with federal statutes, regulations, and the terms and conditions of the award. Condition: The School District informed the engagement team that it was unable to locate all required documentation necessary to support expenditures and compliance with federal program requirements. This affected our ability to complete the required testing over the major program. Cause: The School District does not have a consistent or centralized process for retaining and organizing documentation related to federal program expenditures and compliance requirements. Staff turnover and lack of clear documentation procedures contributed to the unavailability of records. Effect: Due to the absence of required supporting documentation, we were unable to obtain sufficient appropriate audit evidence to support compliance with the federal requirements for the affected programs. As a result, we were unable to determine whether certain transactions were allowable and in compliance with the applicable grant requirements. This represents a material noncompliance with federal regulations and may result in questioned costs or other remedial actions by the granting agency. Questioned Costs: $989,166. This amount represents the total presented on the Schedule of Expenditures of Federal Awards. The entire amount is in question because no testing could be performed as required documentation was not retained by the School District. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement stronger internal controls over document retention, including centralized digital storage systems, regular staff training on federal documentation requirements, and written procedures outlining retention responsibilities. These procedures should ensure that all required documentation is maintained and readily accessible for audit and monitoring purposes. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2021-010 Inability to Test Compliance (Material Weakness) Federal Agency: Department of Education Pass-through Agency: New Hampshire Department of Education Cluster/Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D Passed-through Identification: 20204986 & 20211886 Compliance Requirements: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.334, recipients of federal funds must retain financial and programmatic records, supporting documents, statistical records, and all other records pertinent to a federal award for a period of three years from the date of submission of the final expenditure report. Additionally, per 2 CFR 200.303, recipients must establish and maintain effective internal control over federal awards to ensure compliance with federal statutes, regulations, and the terms and conditions of the award. Condition: The School District informed the engagement team that it was unable to locate all required documentation necessary to support expenditures and compliance with federal program requirements. This affected our ability to complete the required testing over the major program. Cause: The School District does not have a consistent or centralized process for retaining and organizing documentation related to federal program expenditures and compliance requirements. Staff turnover and lack of clear documentation procedures contributed to the unavailability of records. Effect: Due to the absence of required supporting documentation, we were unable to obtain sufficient appropriate audit evidence to support compliance with the federal requirements for the affected programs. As a result, we were unable to determine whether certain transactions were allowable and in compliance with the applicable grant requirements. This represents a material noncompliance with federal regulations and may result in questioned costs or other remedial actions by the granting agency. Questioned Costs: $505,347. This amount represents the total presented on the Schedule of Expenditures of Federal Awards. The entire amount is in question because no testing could be performed as required documentation was not retained by the School District. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement stronger internal controls over document retention, including centralized digital storage systems, regular staff training on federal documentation requirements, and written procedures outlining retention responsibilities. These procedures should ensure that all required documentation is maintained and readily accessible for audit and monitoring purposes. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2021-010 Inability to Test Compliance (Material Weakness) Federal Agency: Department of Education Pass-through Agency: New Hampshire Department of Education Cluster/Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D Passed-through Identification: 20204986 & 20211886 Compliance Requirements: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: In accordance with 2 CFR 200.334, recipients of federal funds must retain financial and programmatic records, supporting documents, statistical records, and all other records pertinent to a federal award for a period of three years from the date of submission of the final expenditure report. Additionally, per 2 CFR 200.303, recipients must establish and maintain effective internal control over federal awards to ensure compliance with federal statutes, regulations, and the terms and conditions of the award. Condition: The School District informed the engagement team that it was unable to locate all required documentation necessary to support expenditures and compliance with federal program requirements. This affected our ability to complete the required testing over the major program. Cause: The School District does not have a consistent or centralized process for retaining and organizing documentation related to federal program expenditures and compliance requirements. Staff turnover and lack of clear documentation procedures contributed to the unavailability of records. Effect: Due to the absence of required supporting documentation, we were unable to obtain sufficient appropriate audit evidence to support compliance with the federal requirements for the affected programs. As a result, we were unable to determine whether certain transactions were allowable and in compliance with the applicable grant requirements. This represents a material noncompliance with federal regulations and may result in questioned costs or other remedial actions by the granting agency. Questioned Costs: $505,347. This amount represents the total presented on the Schedule of Expenditures of Federal Awards. The entire amount is in question because no testing could be performed as required documentation was not retained by the School District. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement stronger internal controls over document retention, including centralized digital storage systems, regular staff training on federal documentation requirements, and written procedures outlining retention responsibilities. These procedures should ensure that all required documentation is maintained and readily accessible for audit and monitoring purposes. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
Criteria: The Company should must establish and maintain effective internal control over federal awards to provide reasonable assurance that the award is managed in compliance with federal statutes, regulations, and the terms and conditions of the award. Adequate documentation must be maintained to support internal control activities and compliance with federal requirements. Statement of Condition: During our walkthroughs and substantive testing, supporting documentation was not available to allow us to evaluate whether required internal controls were performed. The documents were unavailable due to the expiration of the entity’s document retention period and employee turnover, which resulted in the loss of institutional knowledge about the controls performed during the award period. Because the requested documentation could not be provided, we were unable to verify the performance or effectiveness of internal controls related to the compliance requirement tested. Cause of Condition: The entity did not maintain documentation of internal control activities beyond the minimum required retention period and did not have processes in place to preserve institutional knowledge during employee turnover. As a result, supporting records necessary for testing internal controls over federal awards were no longer available. Effect of Condition: Due to the absence of supporting documentation, we were unable to determine whether internal controls over the compliance requirement were properly designed and operating effectively. This results in the inability to test internal controls and assess control risk at a “low” level. Recommendation: We recommend that management (1) strengthen record retention practices to ensure that documentation of internal control activities is preserved in accordance with 2 CFR 200.334 and is available for future audits, (2) implement procedures to maintain institutional knowledge, particularly during periods of employee turnover (e.g., documented policies, cross-training, centralized recordkeeping), and (3) consider extending retention periods for documents supporting high-risk federal programs or key internal control activities. Management should ensure documentation is sufficient to demonstrate compliance and support internal control operations. Identification of Repeat Finding: This is a new finding. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.