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 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, crosstraining, 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 finding is a repeat of the finding noted in the audit for December 31, 2019 as finding 2019-003. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.
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.