Finding 2022-003 Cash Management – Repeat Finding 2021-003 Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context We tested a sample consisting of six cash drawdowns from a total of twenty-two amounting to $264,870. Our audit procedures indicated that $81,023 were not disbursed in a timely manner. In addition, our SEFA reconciliation procedures revealed that an additional $9,497 had not been disbursed timely by the end of the year. As of December 31, 2022, CMSDC had accumulated $206,746 in grant advances, of which $197,249 pertain to 2021. Criteria Uniform Guidance requires that non-federal entities minimize the time elapsing between the transfer of funds and disbursements by the non-federal entity. Per 2 CFR 200.344, unobligated funds must be promptly refunded to the Federal agency that paid those funds. Cause CMSDC did not reconcile expenditures to cash drawdowns. Effect CMSDC did not comply with Uniform Guidance and closed the year with a grant advance of $206,746. Recommendation We recommend that CMSDC updates it policies and procedures to include procedures for reconciling expenditures to cash drawdowns. In addition, we recommend that CMSDC reconciles expenditures and cash drawdowns on a monthly basis. Unobligated funds should also be refunded to the U.S. Department of Commerce. Organization’s Management Response See corrective action plan.
Finding 2022-003 Cash Management – Repeat Finding 2021-003 Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context We tested a sample consisting of six cash drawdowns from a total of twenty-two amounting to $264,870. Our audit procedures indicated that $81,023 were not disbursed in a timely manner. In addition, our SEFA reconciliation procedures revealed that an additional $9,497 had not been disbursed timely by the end of the year. As of December 31, 2022, CMSDC had accumulated $206,746 in grant advances, of which $197,249 pertain to 2021. Criteria Uniform Guidance requires that non-federal entities minimize the time elapsing between the transfer of funds and disbursements by the non-federal entity. Per 2 CFR 200.344, unobligated funds must be promptly refunded to the Federal agency that paid those funds. Cause CMSDC did not reconcile expenditures to cash drawdowns. Effect CMSDC did not comply with Uniform Guidance and closed the year with a grant advance of $206,746. Recommendation We recommend that CMSDC updates it policies and procedures to include procedures for reconciling expenditures to cash drawdowns. In addition, we recommend that CMSDC reconciles expenditures and cash drawdowns on a monthly basis. Unobligated funds should also be refunded to the U.S. Department of Commerce. Organization’s Management Response See corrective action plan.
Finding 2022-003 Cash Management – Repeat Finding 2021-003 Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context We tested a sample consisting of six cash drawdowns from a total of twenty-two amounting to $264,870. Our audit procedures indicated that $81,023 were not disbursed in a timely manner. In addition, our SEFA reconciliation procedures revealed that an additional $9,497 had not been disbursed timely by the end of the year. As of December 31, 2022, CMSDC had accumulated $206,746 in grant advances, of which $197,249 pertain to 2021. Criteria Uniform Guidance requires that non-federal entities minimize the time elapsing between the transfer of funds and disbursements by the non-federal entity. Per 2 CFR 200.344, unobligated funds must be promptly refunded to the Federal agency that paid those funds. Cause CMSDC did not reconcile expenditures to cash drawdowns. Effect CMSDC did not comply with Uniform Guidance and closed the year with a grant advance of $206,746. Recommendation We recommend that CMSDC updates it policies and procedures to include procedures for reconciling expenditures to cash drawdowns. In addition, we recommend that CMSDC reconciles expenditures and cash drawdowns on a monthly basis. Unobligated funds should also be refunded to the U.S. Department of Commerce. Organization’s Management Response See corrective action plan.
2022-004 Internal Controls over Compliance and Compliance with Period of Performance Compliance Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720FDA20GR00287 July 10, 2020 through November 15, 2021 720FDA20GR00216 July 15, 2020 through January 14, 2021 72DFFP20GR00010 March 1, 2020 through May 31, 2021 Criteria or Specific Requirement: In accordance with 2 CFR ?200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by ?200.344(b). When used in connection with a non-Federal entity?s utilization of funds under a Federal award, ?obligations? means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in ?200.71. Condition: During our testing of the period of performance compliance requirement, we selected twenty-five expense samples specifically for grants that began or ended during the year ended September 30, 2022. We also selected nine grant awards with a grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. Out of the twenty-five samples selected for testing, we identified one expense sample in the amount of $1,029 that was incurred after the end of the period of performance. Out of the nine grant awards selected for testing, we noted that expenses were either charged and/or reclassified to two grant awards that already expired prior to fiscal year 2022. Grant awards 720FDA20GR00216 and 72DFFP20GR00010 were charged $100,382 and $130,610, respectively, for the year ended September 30, 2022 even though these grants already concluded per their grant terms, prior to fiscal year 2022. The amount of $100,382 was an overspending of an expired grant which was reclassified in fiscal year 2021 and inadvertently reversed back in the fiscal year 2022 with no impact in financial reporting to the donor. The amount of $130,610 was reclassified to grant award 72DFFP20GR00010 from grant award 72DFFP18GR00019 during fiscal year 2022. It was also noted during this testing that CRS?s new ERP system as currently configured does not restrict recording of expenses and adjustments to grant awards that already expired at the sub-ledger levels where the transactions are initiated. Questioned Costs: Expenditures incurred after the end of the period of performance totaled $1,029 and are considered to be known questioned costs. The amount of $100,382 noted above was not claimed from the federal grantor but it should have not been included in the schedule of expenditures of federal awards for the year ended September 30, 2022. Context: BDO?s testing of the period of performance compliance requirement was performed by examining whether the expenses selected specifically for grants that began or ended during the fiscal year 2022 were incurred within the proper period of performance of the award. The total amount of the twenty-five expense items selected for testing was $194,527 out of the total population of $10,470,570. BDO also performed specific period of performance procedures on the nine grant awards with grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. The total amount of expenditures for the nine grant awards selected for testing was $1,311,595. Samples were selected using a non-statistical approach. Cause: CRS management has documented procedures in place to review expenditures; however, those procedures were not performed to a level of detail to identify expenses that were incurred outside the period of the award. The control procedures are primarily manual as the new ERP system as currently configured does not have capability to restrict recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Effect: While the known questioned costs that resulted from the conditions identified above were not material to the major program, the lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with federal statutes, regulations, and the provisions of the grant agreements. This could ultimately result in additional disallowed costs for the major program. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance of the awards as well as for ensuring that expenses are recorded in the appropriate fiscal year from an accrual basis perspective. We also recommend management work towards enhancing or determining a modification of the ERP system?s capability to restrict the recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Views of Responsible Officials: CRS management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2022-004 Internal Controls over Compliance and Compliance with Period of Performance Compliance Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720FDA20GR00287 July 10, 2020 through November 15, 2021 720FDA20GR00216 July 15, 2020 through January 14, 2021 72DFFP20GR00010 March 1, 2020 through May 31, 2021 Criteria or Specific Requirement: In accordance with 2 CFR ?200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by ?200.344(b). When used in connection with a non-Federal entity?s utilization of funds under a Federal award, ?obligations? means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in ?200.71. Condition: During our testing of the period of performance compliance requirement, we selected twenty-five expense samples specifically for grants that began or ended during the year ended September 30, 2022. We also selected nine grant awards with a grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. Out of the twenty-five samples selected for testing, we identified one expense sample in the amount of $1,029 that was incurred after the end of the period of performance. Out of the nine grant awards selected for testing, we noted that expenses were either charged and/or reclassified to two grant awards that already expired prior to fiscal year 2022. Grant awards 720FDA20GR00216 and 72DFFP20GR00010 were charged $100,382 and $130,610, respectively, for the year ended September 30, 2022 even though these grants already concluded per their grant terms, prior to fiscal year 2022. The amount of $100,382 was an overspending of an expired grant which was reclassified in fiscal year 2021 and inadvertently reversed back in the fiscal year 2022 with no impact in financial reporting to the donor. The amount of $130,610 was reclassified to grant award 72DFFP20GR00010 from grant award 72DFFP18GR00019 during fiscal year 2022. It was also noted during this testing that CRS?s new ERP system as currently configured does not restrict recording of expenses and adjustments to grant awards that already expired at the sub-ledger levels where the transactions are initiated. Questioned Costs: Expenditures incurred after the end of the period of performance totaled $1,029 and are considered to be known questioned costs. The amount of $100,382 noted above was not claimed from the federal grantor but it should have not been included in the schedule of expenditures of federal awards for the year ended September 30, 2022. Context: BDO?s testing of the period of performance compliance requirement was performed by examining whether the expenses selected specifically for grants that began or ended during the fiscal year 2022 were incurred within the proper period of performance of the award. The total amount of the twenty-five expense items selected for testing was $194,527 out of the total population of $10,470,570. BDO also performed specific period of performance procedures on the nine grant awards with grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. The total amount of expenditures for the nine grant awards selected for testing was $1,311,595. Samples were selected using a non-statistical approach. Cause: CRS management has documented procedures in place to review expenditures; however, those procedures were not performed to a level of detail to identify expenses that were incurred outside the period of the award. The control procedures are primarily manual as the new ERP system as currently configured does not have capability to restrict recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Effect: While the known questioned costs that resulted from the conditions identified above were not material to the major program, the lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with federal statutes, regulations, and the provisions of the grant agreements. This could ultimately result in additional disallowed costs for the major program. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance of the awards as well as for ensuring that expenses are recorded in the appropriate fiscal year from an accrual basis perspective. We also recommend management work towards enhancing or determining a modification of the ERP system?s capability to restrict the recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Views of Responsible Officials: CRS management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2022-004 Internal Controls over Compliance and Compliance with Period of Performance Compliance Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720FDA20GR00287 July 10, 2020 through November 15, 2021 720FDA20GR00216 July 15, 2020 through January 14, 2021 72DFFP20GR00010 March 1, 2020 through May 31, 2021 Criteria or Specific Requirement: In accordance with 2 CFR ?200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by ?200.344(b). When used in connection with a non-Federal entity?s utilization of funds under a Federal award, ?obligations? means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in ?200.71. Condition: During our testing of the period of performance compliance requirement, we selected twenty-five expense samples specifically for grants that began or ended during the year ended September 30, 2022. We also selected nine grant awards with a grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. Out of the twenty-five samples selected for testing, we identified one expense sample in the amount of $1,029 that was incurred after the end of the period of performance. Out of the nine grant awards selected for testing, we noted that expenses were either charged and/or reclassified to two grant awards that already expired prior to fiscal year 2022. Grant awards 720FDA20GR00216 and 72DFFP20GR00010 were charged $100,382 and $130,610, respectively, for the year ended September 30, 2022 even though these grants already concluded per their grant terms, prior to fiscal year 2022. The amount of $100,382 was an overspending of an expired grant which was reclassified in fiscal year 2021 and inadvertently reversed back in the fiscal year 2022 with no impact in financial reporting to the donor. The amount of $130,610 was reclassified to grant award 72DFFP20GR00010 from grant award 72DFFP18GR00019 during fiscal year 2022. It was also noted during this testing that CRS?s new ERP system as currently configured does not restrict recording of expenses and adjustments to grant awards that already expired at the sub-ledger levels where the transactions are initiated. Questioned Costs: Expenditures incurred after the end of the period of performance totaled $1,029 and are considered to be known questioned costs. The amount of $100,382 noted above was not claimed from the federal grantor but it should have not been included in the schedule of expenditures of federal awards for the year ended September 30, 2022. Context: BDO?s testing of the period of performance compliance requirement was performed by examining whether the expenses selected specifically for grants that began or ended during the fiscal year 2022 were incurred within the proper period of performance of the award. The total amount of the twenty-five expense items selected for testing was $194,527 out of the total population of $10,470,570. BDO also performed specific period of performance procedures on the nine grant awards with grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. The total amount of expenditures for the nine grant awards selected for testing was $1,311,595. Samples were selected using a non-statistical approach. Cause: CRS management has documented procedures in place to review expenditures; however, those procedures were not performed to a level of detail to identify expenses that were incurred outside the period of the award. The control procedures are primarily manual as the new ERP system as currently configured does not have capability to restrict recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Effect: While the known questioned costs that resulted from the conditions identified above were not material to the major program, the lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with federal statutes, regulations, and the provisions of the grant agreements. This could ultimately result in additional disallowed costs for the major program. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance of the awards as well as for ensuring that expenses are recorded in the appropriate fiscal year from an accrual basis perspective. We also recommend management work towards enhancing or determining a modification of the ERP system?s capability to restrict the recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Views of Responsible Officials: CRS management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2022-004 Internal Controls over Compliance and Compliance with Period of Performance Compliance Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720FDA20GR00287 July 10, 2020 through November 15, 2021 720FDA20GR00216 July 15, 2020 through January 14, 2021 72DFFP20GR00010 March 1, 2020 through May 31, 2021 Criteria or Specific Requirement: In accordance with 2 CFR ?200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by ?200.344(b). When used in connection with a non-Federal entity?s utilization of funds under a Federal award, ?obligations? means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in ?200.71. Condition: During our testing of the period of performance compliance requirement, we selected twenty-five expense samples specifically for grants that began or ended during the year ended September 30, 2022. We also selected nine grant awards with a grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. Out of the twenty-five samples selected for testing, we identified one expense sample in the amount of $1,029 that was incurred after the end of the period of performance. Out of the nine grant awards selected for testing, we noted that expenses were either charged and/or reclassified to two grant awards that already expired prior to fiscal year 2022. Grant awards 720FDA20GR00216 and 72DFFP20GR00010 were charged $100,382 and $130,610, respectively, for the year ended September 30, 2022 even though these grants already concluded per their grant terms, prior to fiscal year 2022. The amount of $100,382 was an overspending of an expired grant which was reclassified in fiscal year 2021 and inadvertently reversed back in the fiscal year 2022 with no impact in financial reporting to the donor. The amount of $130,610 was reclassified to grant award 72DFFP20GR00010 from grant award 72DFFP18GR00019 during fiscal year 2022. It was also noted during this testing that CRS?s new ERP system as currently configured does not restrict recording of expenses and adjustments to grant awards that already expired at the sub-ledger levels where the transactions are initiated. Questioned Costs: Expenditures incurred after the end of the period of performance totaled $1,029 and are considered to be known questioned costs. The amount of $100,382 noted above was not claimed from the federal grantor but it should have not been included in the schedule of expenditures of federal awards for the year ended September 30, 2022. Context: BDO?s testing of the period of performance compliance requirement was performed by examining whether the expenses selected specifically for grants that began or ended during the fiscal year 2022 were incurred within the proper period of performance of the award. The total amount of the twenty-five expense items selected for testing was $194,527 out of the total population of $10,470,570. BDO also performed specific period of performance procedures on the nine grant awards with grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. The total amount of expenditures for the nine grant awards selected for testing was $1,311,595. Samples were selected using a non-statistical approach. Cause: CRS management has documented procedures in place to review expenditures; however, those procedures were not performed to a level of detail to identify expenses that were incurred outside the period of the award. The control procedures are primarily manual as the new ERP system as currently configured does not have capability to restrict recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Effect: While the known questioned costs that resulted from the conditions identified above were not material to the major program, the lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with federal statutes, regulations, and the provisions of the grant agreements. This could ultimately result in additional disallowed costs for the major program. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance of the awards as well as for ensuring that expenses are recorded in the appropriate fiscal year from an accrual basis perspective. We also recommend management work towards enhancing or determining a modification of the ERP system?s capability to restrict the recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Views of Responsible Officials: CRS management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2022-004 Internal Controls over Compliance and Compliance with Period of Performance Compliance Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720FDA20GR00287 July 10, 2020 through November 15, 2021 720FDA20GR00216 July 15, 2020 through January 14, 2021 72DFFP20GR00010 March 1, 2020 through May 31, 2021 Criteria or Specific Requirement: In accordance with 2 CFR ?200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by ?200.344(b). When used in connection with a non-Federal entity?s utilization of funds under a Federal award, ?obligations? means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in ?200.71. Condition: During our testing of the period of performance compliance requirement, we selected twenty-five expense samples specifically for grants that began or ended during the year ended September 30, 2022. We also selected nine grant awards with a grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. Out of the twenty-five samples selected for testing, we identified one expense sample in the amount of $1,029 that was incurred after the end of the period of performance. Out of the nine grant awards selected for testing, we noted that expenses were either charged and/or reclassified to two grant awards that already expired prior to fiscal year 2022. Grant awards 720FDA20GR00216 and 72DFFP20GR00010 were charged $100,382 and $130,610, respectively, for the year ended September 30, 2022 even though these grants already concluded per their grant terms, prior to fiscal year 2022. The amount of $100,382 was an overspending of an expired grant which was reclassified in fiscal year 2021 and inadvertently reversed back in the fiscal year 2022 with no impact in financial reporting to the donor. The amount of $130,610 was reclassified to grant award 72DFFP20GR00010 from grant award 72DFFP18GR00019 during fiscal year 2022. It was also noted during this testing that CRS?s new ERP system as currently configured does not restrict recording of expenses and adjustments to grant awards that already expired at the sub-ledger levels where the transactions are initiated. Questioned Costs: Expenditures incurred after the end of the period of performance totaled $1,029 and are considered to be known questioned costs. The amount of $100,382 noted above was not claimed from the federal grantor but it should have not been included in the schedule of expenditures of federal awards for the year ended September 30, 2022. Context: BDO?s testing of the period of performance compliance requirement was performed by examining whether the expenses selected specifically for grants that began or ended during the fiscal year 2022 were incurred within the proper period of performance of the award. The total amount of the twenty-five expense items selected for testing was $194,527 out of the total population of $10,470,570. BDO also performed specific period of performance procedures on the nine grant awards with grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. The total amount of expenditures for the nine grant awards selected for testing was $1,311,595. Samples were selected using a non-statistical approach. Cause: CRS management has documented procedures in place to review expenditures; however, those procedures were not performed to a level of detail to identify expenses that were incurred outside the period of the award. The control procedures are primarily manual as the new ERP system as currently configured does not have capability to restrict recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Effect: While the known questioned costs that resulted from the conditions identified above were not material to the major program, the lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with federal statutes, regulations, and the provisions of the grant agreements. This could ultimately result in additional disallowed costs for the major program. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance of the awards as well as for ensuring that expenses are recorded in the appropriate fiscal year from an accrual basis perspective. We also recommend management work towards enhancing or determining a modification of the ERP system?s capability to restrict the recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Views of Responsible Officials: CRS management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2022-004 Internal Controls over Compliance and Compliance with Period of Performance Compliance Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720FDA20GR00287 July 10, 2020 through November 15, 2021 720FDA20GR00216 July 15, 2020 through January 14, 2021 72DFFP20GR00010 March 1, 2020 through May 31, 2021 Criteria or Specific Requirement: In accordance with 2 CFR ?200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by ?200.344(b). When used in connection with a non-Federal entity?s utilization of funds under a Federal award, ?obligations? means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in ?200.71. Condition: During our testing of the period of performance compliance requirement, we selected twenty-five expense samples specifically for grants that began or ended during the year ended September 30, 2022. We also selected nine grant awards with a grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. Out of the twenty-five samples selected for testing, we identified one expense sample in the amount of $1,029 that was incurred after the end of the period of performance. Out of the nine grant awards selected for testing, we noted that expenses were either charged and/or reclassified to two grant awards that already expired prior to fiscal year 2022. Grant awards 720FDA20GR00216 and 72DFFP20GR00010 were charged $100,382 and $130,610, respectively, for the year ended September 30, 2022 even though these grants already concluded per their grant terms, prior to fiscal year 2022. The amount of $100,382 was an overspending of an expired grant which was reclassified in fiscal year 2021 and inadvertently reversed back in the fiscal year 2022 with no impact in financial reporting to the donor. The amount of $130,610 was reclassified to grant award 72DFFP20GR00010 from grant award 72DFFP18GR00019 during fiscal year 2022. It was also noted during this testing that CRS?s new ERP system as currently configured does not restrict recording of expenses and adjustments to grant awards that already expired at the sub-ledger levels where the transactions are initiated. Questioned Costs: Expenditures incurred after the end of the period of performance totaled $1,029 and are considered to be known questioned costs. The amount of $100,382 noted above was not claimed from the federal grantor but it should have not been included in the schedule of expenditures of federal awards for the year ended September 30, 2022. Context: BDO?s testing of the period of performance compliance requirement was performed by examining whether the expenses selected specifically for grants that began or ended during the fiscal year 2022 were incurred within the proper period of performance of the award. The total amount of the twenty-five expense items selected for testing was $194,527 out of the total population of $10,470,570. BDO also performed specific period of performance procedures on the nine grant awards with grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. The total amount of expenditures for the nine grant awards selected for testing was $1,311,595. Samples were selected using a non-statistical approach. Cause: CRS management has documented procedures in place to review expenditures; however, those procedures were not performed to a level of detail to identify expenses that were incurred outside the period of the award. The control procedures are primarily manual as the new ERP system as currently configured does not have capability to restrict recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Effect: While the known questioned costs that resulted from the conditions identified above were not material to the major program, the lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with federal statutes, regulations, and the provisions of the grant agreements. This could ultimately result in additional disallowed costs for the major program. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance of the awards as well as for ensuring that expenses are recorded in the appropriate fiscal year from an accrual basis perspective. We also recommend management work towards enhancing or determining a modification of the ERP system?s capability to restrict the recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Views of Responsible Officials: CRS management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding Number: 2022-072 Prior Year Finding Number: 2021-057 Compliance Requirement: Period of Performance Program: U.S. Department of Health and Human Services Social Services Block Grant ALN: 93.667 Award #: Various Award Year: Various Government Department/Agency: Department of Human Services (DHS) Criteria – A Non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Additionally, the Uniform Guidance in 2 CFR Section 200.344(b), states that unless the federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Further, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires the non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonable ensure compliance with Federal statutes, regulations, and other terms and conditions of the Federal Award. Condition - We sampled and selected 24 out of 164 expenditures and found 7 expenditures that were charged to the grant during the liquidation period and incurred outside the period of availability. Such expenditures totaled $4,152. Further, outside of our sample, we found six expenditures that were charged to a grant after the liquidation period. Additionally, internal controls do not appear to be operating at a level of precision to ensure grant expenditures are charged to the correct grant and within the allowable period of performance. Questioned Costs – $6,934 Context – This is a condition identified per review of DHS’ compliance with the specified requirements using a statistically valid sample. Total amount of expenditures subject to sampling were $183,568. Total amount sampled is $35,873. Effect - DHS is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding. Cause – DHS does not appear to have adequate policies and procedures in place to ensure compliance with the required period of performance stipulations. Recommendation – We recommend that DHS strengthen its process with respect to charging expenditures between various grant awards. We also recommend that DHS enhance its review process to properly determine the activities of each grant relative to the appropriate period of performance. Views of Responsible Officials - The Government concurs with the auditor’s findings and recommendations. As part of the close-out process, all open purchase orders are now submitted to the Department of Finance for closure. The grant close-out process has been shifted to the OMB to ensure the grant is no longer available for transaction entries or liquidations. Additionally, a dedicated Fiscal Analyst is being integrated into the workflow to ensure compliance. The planned corrective actions are presented in the Government’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding No. 2022-016 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D20AP00005 and D20AP00037 Area: Period of Performance Questioned Costs: $494,836 Criteria: 1. A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). 2. A non-federal entity must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award (2 CFR section 200.344(b)). Condition: Of eight expenditures tested, aggregating $593,531 of a total population of $692,970, the following were noted: 1. For four (or 50%), CNMI was unable to provide supporting documents, such as purchase orders or contracts, to support that expenditures were incurred within the period of performance. 2. For one (or 13%), CNMI was unable to provide the cancelled check to support that the expenditure was liquidated within 120 days after the end date of the period of performance. Cause: The CNMI did not provide sufficient and appropriate audit evidence to substantiate the expenditures over compliance with applicable period of performance requirement. Effect: The CNMI is in noncompliance with applicable period of performance requirements and questioned cost of $494,836 result. Recommendation: CNMI should provide timely and consistent communication with the auditors to avoid future noncompliance due to lack of supporting evidence. Having the correct documentation is crucial in determining compliance to each requirement. Views of Responsible Officials: Condition 1 - The Office of Grant Management (OGM) disagrees with this finding. Due to internal scheduling constraints and the compressed timeline required to complete the FY2022 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, OGM maintains all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Based on our records, grant award D20AP00005 remains active with a period of performance extending through September 30, 2025, while grant award D20AP00037 was closed on September 30, 2024. Both grants remained operational well beyond the originally prescribed September 30, 2022 deadline. Given the extended period of performance authorized by the awarding agency, all associated questioned costs ($494,660.00) are supported by active grant activity and should be deemed allowable. Accordingly, OGM respectfully requests that these questioned costs be removed, as they reflect legitimate expenditures incurred within the approved grant periods. Condition 2 - CIP agrees with the finding. The responsible official will report progress on corrective actions to the CNMI leadership and maintain documentation of all implemented changes. Evidence of compliance (updated policies, training records, and self-audit reports) will be provided to the auditors upon request. Refer to CNMI’s Corrective Action Plan for additional information. Auditor Response: Condition 1 - CNMI states disagreement; however, CNMI also acknowledges that documentation supporting program costs were not provided. Questioned costs are retained, as costs at the time of the audit were not supported by adequate documentation.
Finding No. 2022-024 Federal Agency: U.S. Department of the Treasury AL Program: 21.023 Emergency Rental Assistance Program Federal Award No.: 20010001/000021 Area: Period of Performance Questioned Costs: $26,329 Criteria: 1. In accordance with 2 CFR 200.344(c), the recipient must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the conclusion of the period of performance; 2. In accordance with the U.S. Department of Treasury closeout activities guidance dated 09/16/22, obligated funds may be expended by grantees for up to 120 calendar days after the end of the award period of performance for allowable administrative activities; and Condition: Of fifty ERA 1 expenditures tested, aggregating $90,179 of a total population of $191,896, the following were noted: 1. For twenty-seven (or 54%), costs were liquidated after the grant award’s end of the 120-day liquidation period of 01/30/23. 2. For one (or 2%), obligating and liquidation documentations were not provided. Accordingly, the CNMI was not able to substantiate that the cost was incurred/obligated and liquidated within the period of performance. Cause: CNMI did not enforce compliance with the applicable period of performance requirements and lacks monitoring control over the verification that costs charged to the program were incurred/obligated and liquidated within the period of performance. Effect: CNMI is in noncompliance with the applicable period of performance requirements and questioned costs of $26,329 result. Recommendation: CNMI should strengthen and enforce compliance with the applicable period of performance requirements and implement and enforce monitoring controls over program costs to ensure that costs charged to the program are within the specified period of performance and implement and establish systematic filing of relevant documentation for easy retrieval. Views of Responsible Officials: Condition 1 - The Office of Grant Management (OGM) disagrees with this finding. OGM recollects prior guidance and program discussions indicating that U.S. Territories administering ERA were afforded greater flexibility in the period of performance, in recognition of their geographic remoteness and the additional time required to receive technical assistance and implement compliant systems. This understanding informed OGM’s administration of ERA funds. Additionally, several disbursed checks were returned, which created reconciliation delays and made it difficult to ascertain the true unobligated balance of the grant until sufficient time had passed for all transactions to clear. To address compliance concerns, CNMI officials traveled to Washington, D.C. in February 2025 to meet with U.S. Treasury representatives and resolve outstanding ERA1 documentation issues. Following those meetings, OGM submitted the necessary reports and initiated the closeout process for ERA1 in accordance with federal requirements. The questioned cost of $26,329 reflects expenditures that were directed toward eligible households impacted by COVID-19. These expenditures were necessary, reasonable, and allocable under 2 CFR 200.403, and fully aligned with the statutory purpose of ERA to prevent housing instability. Disallowing these costs would effectively negate assistance that was properly delivered to beneficiaries and undermine the program’s objective. For these reasons, OGM respectfully requests that the questioned cost be removed. Condition 2 - The Office of Grant Management (OGM) disagrees with this finding. Due to internal scheduling constraints and the compressed timeline required to complete the FY2022 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, OGM maintains all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Refer to CNMI’s Corrective Action Plan for additional information. Auditor Response: Condition 1 - Documentation of the afforded flexibility over the period of performance requirements for the CNMI’s ERA grants was not provided. Questioned costs are retained, as costs at the time of the audit were not supported by adequate documentation. Condition 2 - CNMI states disagreement; however, CNMI acknowledges that documentation supporting program costs were not provided.
Finding No. 2022-035 Federal Agency: U.S. Department of Health and Human Services AL Program: 93.767 Children’s Health Insurance Program Federal Award No.: 7510515, 7520515 Area: Period of Performance Questioned Costs: $38,556 Criteria: 1. A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). 2. A non-federal entity must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award (2 CFR section 200.344(b)). Condition: CNMI was unable to provide supporting documents (i.e. invoices, contracts, etc.) to support compliance with period of performance requirements for two (or 25%) of eight expenditures tested totaling $2,105,155 of a total population of $2,163,439 . Cause: CNMI lacks monitoring control over adequate documentation and systematic filing of relevant documentations supporting program costs. Effect: CNMI is in noncompliance with applicable period of performance requirements and questioned cost of $38,556 result. Recommendation: CNMI should implement more stringent record-keeping mechanisms to ensure timely submission of audit documents upon request of the auditors used for the testing of compliance requirements. Views of Responsible Officials: The CNMI Medicaid Office disagrees with this finding. Due to internal scheduling constraints and the compressed timeline required to complete the FY2022 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, the office maintains all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Refer to CNMI’s Corrective Action Plan for additional information. Auditor Response: CNMI states disagreement; however, CNMI also acknowledges that documentation supporting program costs were not provided.
Finding No. 2022-042 Federal Agency: U.S. Department of Homeland Security AL Program: 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Federal Award No.: 4235DRMPP00000491; 4235DRMPP00000951; 4396DRMPP00000041; 4511DRMPP00000271; 4511DRMPP00000081 Area: Period of Performance Questioned Costs: $423,234 Criteria: In accordance with 2 CFR §200.344(c), the recipient must liquidate all financial obligations incurred under the Federal award not later than 120 calendar days after the conclusion of the period of performance. When justified, the Federal agency or pass-through entity may approve extensions for the recipient or subrecipient. Condition: Of twenty-nine nonpayroll expenditures tested, aggregating $2,973,162, of a total population of $2,973,162, the following were noted: 1. For four (or 14%), the liquidation occurred beyond the project worksheet’s liquidation date or 120 days from the project worksheet end date. Grant extension documentation was not provided. 2. For one (or 3%), the obligation occurred beyond the project worksheet end date of 06/30/2022. Grant extension documentation was not provided. Cause: The CNMI did not effectively monitor compliance with applicable period of performance requirements. Effect: The CNMI is in noncompliance with the period of performance requirements, and questioned costs of $423,234 result. Recommendation: Responsible personnel should monitor check payments to allow for timely liquidation. Grantor approval should be sought, as necessary. Views of Responsible Officials: Condition 1 - The Public Assistance Office agrees that the liquidation for DR4235MP (PW 95), was processed after the liquidation deadline; however, disagrees for DR4396MP (PW 4) as the liquidation was done prior to the closeout deadline of December 31, 2022 and liquidations for DR4511MP (PW 27) and DR4511MP (PW 8) were done prior to the closeout date of June 30, 2025. Condition 2 - The Public Assistance Office disagrees with this finding. The invoice was dated and recorded after the period of performance (June 30, 2022), but date of actual work completed as shown on the Megger Test was May 20, 2022. The Public Assistance Office acknowledges that the record of the Megger Test had not been submitted to the auditors when submitting documentation. Refer to CNMI’s Corrective Action Plan for additional information. Auditor Response: Condition 1 - Expenditures were liquidated after the liquidation period of performance end date. Condition 2 - The transaction was obligated in September 2022, which is after the period of performance end date of June 30, 2022.
U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the fiscal year were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The Town is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the fiscal year were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The Town is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the fiscal year were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The Town is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the fiscal year were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The Town is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Human Services made payments under the Vocational Rehabilitation program outside of the period of performance for the 2019 grant award which had a period of performance of 10/1/18 - 9/30/19 with an allowable liquidation period through 1/31/2021. More specifically, the program charged $2,454 to the 2019 grant award when the underlying obligations actually occurred during the 2020 grant award period of performance. CRITERIA The following criteria note that Federal funds must be obligated by the end of the two-year period of performance window and those obligations must be liquidated within 120 days after the end date of period of performance. 2 CFR 200.344 requires: " Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.? 34 CFR 361.64 requires: " (a) Except as provided in paragraph (b) of this section, any Federal funds, including reallotted funds, that are appropriated for a fiscal year to carry out a program under this part that are not obligated by the State by the beginning of the succeeding fiscal year and any program income received during a fiscal year that is not obligated by the State by the beginning of the succeeding fiscal year remain available for obligation by the State during that succeeding fiscal year. (b) Federal funds appropriated for a fiscal year remain available for obligation in the succeeding fiscal year only to the extent that the State met the matching requirement for those Federal funds by obligating, in accordance with 34 CFR 76.707, the non-Federal share in the fiscal year for which the funds were appropriated." The following criteria pertains to the establishment and maintenance of effective internal control to ensure payments are made within the correct period of performance. 2 CFR 200.303 states the non-Federal entity must, "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." CAUSE The Department of Human Services, Vocational Rehabilitation Program, review of the expenditure period of performance, as outlined in its period of performance procedures, were not followed. Therefore, the grant award monitoring procedures were unable to detect payments made outside of the period of performance. EFFECT Unallowable costs totaling $2,454 were charged to the 2019 grant award with a total projected questioned cost amount of $41,717. CONTEXT The Department of Human Services, Vocational Rehabilitation program, had expenditures of $412,720 after the obligation period for the 2019 and 2020 awards. Of this amount, one payment totaling $2,454 was identified by sampling as an error. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2020-019 was reported in the immediate prior year. Findings 2018-031 and 2016-053 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Human Services follow its procedures to prevent and detect Vocational Rehabilitation payments from occurring outside the period of performance. DEPARTMENT OF HUMAN SERVICES RESPONSE The Department of Health and Human Services agrees with the recommendation. See ?Management?s Response and Corrective Action? section of this report.
2022-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster ? CFDA 84.027 & 84.173 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2021-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2022-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster ? CFDA 84.027 & 84.173 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2021-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2022-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster ? CFDA 84.027 & 84.173 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2021-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2022-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster ? CFDA 84.027 & 84.173 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2021-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2022-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster ? CFDA 84.027 & 84.173 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2021-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2022-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster ? CFDA 84.027 & 84.173 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2021-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2022-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster ? CFDA 84.027 & 84.173 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2021-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2022-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster ? CFDA 84.027 & 84.173 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2021-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2022-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster ? CFDA 84.027 & 84.173 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2021-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2022-005: Internal Control Over Compliance and Compliance with Period of Performance Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria - CFR ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its grants? period of performance process. In accordance with CFR Section 200.403(h), cost must be incurred during the approved budget period. The federal awarding agency is authorized at its discretion to waive prior written approvals to carry forward unobligated balances to subsequent budget period pursuant to ?200.308(e)(3). In accordance with CFR Section 200.458, pre-award costs are those incurred prior to the effective date of the federal award or subaward directly pursuant to the negotiation and in anticipation of the federal award where such costs are necessary for efficient and timely performance of the scope of the work. Such costs are allowable only to the extent they would have been allowable if incurred after the date of the federal award and only with the written approval of the federal awarding agency. In accordance with CFR Section 200.344, the federal awarding agency or pass-through entity will close out the federal award when it determines that all applicable administrative actions and all required work of the federal award have been completed by the nonfederal entity. Per CFR Section 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance. Condition ? During our testing of period of performance, we noted exceptions in the ability of management to support expenditures were incurred and charged to federal programs within the period of performance. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were incurred during the period of performance and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect - The lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with laws, regulations, and the provisions of grant agreements, which could ultimately lead to expenditures not being charged to the major programs in the correct period. Questioned Costs ? $29,459 Context: Assistance Listing Number: 19.016 During our testing of the period of performance compliance requirement for grant award periods that ended during the fiscal year, we sampled 12 expenditures, totaling $292,901, for the Iraq Assistance Program and noted one item amounting to $28,766 did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Additionally, during our testing of the period of performance compliance requirement for grant costs incurred throughout the year, we sampled 40 expenditures, totaling $11,811, for the Iraq Assistance Programs and noted that four items, totaling $672, did not have proper documentation for the allocation of the expenditure. Assistance Listing Number: 19.518 During our testing of the period of performance compliance requirement for grant award periods that started and ended during the fiscal year, we sampled 81 expenditures, totaling $15,252, for the Overseas Refugee Assistance Program for Western Hemisphere and noted two items, totaling $21, did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend that the Organization ensure its policies and procedures ensure that documentation of when the expenditure was incurred and liquidated is maintained and that these policies and procedures are followed on a consistent basis. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with the period of performance compliance requirements. Management through the local offices has already developed a policy to ensure that the period of performance is adhered to.
2022-005: Internal Control Over Compliance and Compliance with Period of Performance Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria - CFR ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its grants? period of performance process. In accordance with CFR Section 200.403(h), cost must be incurred during the approved budget period. The federal awarding agency is authorized at its discretion to waive prior written approvals to carry forward unobligated balances to subsequent budget period pursuant to ?200.308(e)(3). In accordance with CFR Section 200.458, pre-award costs are those incurred prior to the effective date of the federal award or subaward directly pursuant to the negotiation and in anticipation of the federal award where such costs are necessary for efficient and timely performance of the scope of the work. Such costs are allowable only to the extent they would have been allowable if incurred after the date of the federal award and only with the written approval of the federal awarding agency. In accordance with CFR Section 200.344, the federal awarding agency or pass-through entity will close out the federal award when it determines that all applicable administrative actions and all required work of the federal award have been completed by the nonfederal entity. Per CFR Section 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance. Condition ? During our testing of period of performance, we noted exceptions in the ability of management to support expenditures were incurred and charged to federal programs within the period of performance. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were incurred during the period of performance and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect - The lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with laws, regulations, and the provisions of grant agreements, which could ultimately lead to expenditures not being charged to the major programs in the correct period. Questioned Costs ? $29,459 Context: Assistance Listing Number: 19.016 During our testing of the period of performance compliance requirement for grant award periods that ended during the fiscal year, we sampled 12 expenditures, totaling $292,901, for the Iraq Assistance Program and noted one item amounting to $28,766 did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Additionally, during our testing of the period of performance compliance requirement for grant costs incurred throughout the year, we sampled 40 expenditures, totaling $11,811, for the Iraq Assistance Programs and noted that four items, totaling $672, did not have proper documentation for the allocation of the expenditure. Assistance Listing Number: 19.518 During our testing of the period of performance compliance requirement for grant award periods that started and ended during the fiscal year, we sampled 81 expenditures, totaling $15,252, for the Overseas Refugee Assistance Program for Western Hemisphere and noted two items, totaling $21, did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend that the Organization ensure its policies and procedures ensure that documentation of when the expenditure was incurred and liquidated is maintained and that these policies and procedures are followed on a consistent basis. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with the period of performance compliance requirements. Management through the local offices has already developed a policy to ensure that the period of performance is adhered to.
2022-006: Internal Control Over Compliance and Compliance with Period of Performance Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria ? CFR ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its grants? period of performance process. In accordance with CFR Section 200.403(h), cost must be incurred during the approved budget period. The federal awarding agency is authorized at its discretion to waive prior written approvals to carry forward unobligated balances to subsequent budget period pursuant to ?200.308(e)(3). In accordance with CFR Section 200.458, pre-award costs are those incurred prior to the effective date of the federal award or subaward directly pursuant to the negotiation and in anticipation of the federal award where such costs are necessary for efficient and timely performance of the scope of the work. Such costs are allowable only to the extent they would have been allowable if incurred after the date of the federal award and only with the written approval of the federal awarding agency. In accordance with CFR Section 200.344, the federal awarding agency or pass-through entity will close out the federal award when it determines that all applicable administrative actions and all required work of the federal award have been completed by the nonfederal entity. Per CFR Section 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance. Condition ? During our testing of period of performance, we noted exceptions where expenditures were incurred outside of the grant?s performance period. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were incurred during the period of performance and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect - The lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with law and regulations and possible loss of funding for the related program. Questioned Costs ? $125 Context: During our testing of the allowable costs/cost principles compliance requirements, we sampled 25 nonpayroll expenditures, totaling $6,365, for the Overseas Refugee Assistance Program for Western Hemisphere and noted that four items, totaling $125, were incurred and paid outside of the grant award period. Repeat Finding - This finding is a repeat finding from prior year. This finding was reported as finding 2021-001 in the 2021 reporting package. Recommendation - We recommend management revisits and considers revising its internal procedures around detecting expenditures incurred outside of the period of performance of the awards. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with the period of performance compliance requirements. Management is emphasizing prompt period closing to ensure that no items are recorded in the wrong period.
2022-005: Internal Control Over Compliance and Compliance with Period of Performance Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria - CFR ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its grants? period of performance process. In accordance with CFR Section 200.403(h), cost must be incurred during the approved budget period. The federal awarding agency is authorized at its discretion to waive prior written approvals to carry forward unobligated balances to subsequent budget period pursuant to ?200.308(e)(3). In accordance with CFR Section 200.458, pre-award costs are those incurred prior to the effective date of the federal award or subaward directly pursuant to the negotiation and in anticipation of the federal award where such costs are necessary for efficient and timely performance of the scope of the work. Such costs are allowable only to the extent they would have been allowable if incurred after the date of the federal award and only with the written approval of the federal awarding agency. In accordance with CFR Section 200.344, the federal awarding agency or pass-through entity will close out the federal award when it determines that all applicable administrative actions and all required work of the federal award have been completed by the nonfederal entity. Per CFR Section 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance. Condition ? During our testing of period of performance, we noted exceptions in the ability of management to support expenditures were incurred and charged to federal programs within the period of performance. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were incurred during the period of performance and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect - The lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with laws, regulations, and the provisions of grant agreements, which could ultimately lead to expenditures not being charged to the major programs in the correct period. Questioned Costs ? $29,459 Context: Assistance Listing Number: 19.016 During our testing of the period of performance compliance requirement for grant award periods that ended during the fiscal year, we sampled 12 expenditures, totaling $292,901, for the Iraq Assistance Program and noted one item amounting to $28,766 did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Additionally, during our testing of the period of performance compliance requirement for grant costs incurred throughout the year, we sampled 40 expenditures, totaling $11,811, for the Iraq Assistance Programs and noted that four items, totaling $672, did not have proper documentation for the allocation of the expenditure. Assistance Listing Number: 19.518 During our testing of the period of performance compliance requirement for grant award periods that started and ended during the fiscal year, we sampled 81 expenditures, totaling $15,252, for the Overseas Refugee Assistance Program for Western Hemisphere and noted two items, totaling $21, did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend that the Organization ensure its policies and procedures ensure that documentation of when the expenditure was incurred and liquidated is maintained and that these policies and procedures are followed on a consistent basis. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with the period of performance compliance requirements. Management through the local offices has already developed a policy to ensure that the period of performance is adhered to.
2022-006: Internal Control Over Compliance and Compliance with Period of Performance Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria ? CFR ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its grants? period of performance process. In accordance with CFR Section 200.403(h), cost must be incurred during the approved budget period. The federal awarding agency is authorized at its discretion to waive prior written approvals to carry forward unobligated balances to subsequent budget period pursuant to ?200.308(e)(3). In accordance with CFR Section 200.458, pre-award costs are those incurred prior to the effective date of the federal award or subaward directly pursuant to the negotiation and in anticipation of the federal award where such costs are necessary for efficient and timely performance of the scope of the work. Such costs are allowable only to the extent they would have been allowable if incurred after the date of the federal award and only with the written approval of the federal awarding agency. In accordance with CFR Section 200.344, the federal awarding agency or pass-through entity will close out the federal award when it determines that all applicable administrative actions and all required work of the federal award have been completed by the nonfederal entity. Per CFR Section 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance. Condition ? During our testing of period of performance, we noted exceptions where expenditures were incurred outside of the grant?s performance period. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were incurred during the period of performance and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect - The lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with law and regulations and possible loss of funding for the related program. Questioned Costs ? $125 Context: During our testing of the allowable costs/cost principles compliance requirements, we sampled 25 nonpayroll expenditures, totaling $6,365, for the Overseas Refugee Assistance Program for Western Hemisphere and noted that four items, totaling $125, were incurred and paid outside of the grant award period. Repeat Finding - This finding is a repeat finding from prior year. This finding was reported as finding 2021-001 in the 2021 reporting package. Recommendation - We recommend management revisits and considers revising its internal procedures around detecting expenditures incurred outside of the period of performance of the awards. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with the period of performance compliance requirements. Management is emphasizing prompt period closing to ensure that no items are recorded in the wrong period.
2022-005: Internal Control Over Compliance and Compliance with Period of Performance Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria - CFR ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its grants? period of performance process. In accordance with CFR Section 200.403(h), cost must be incurred during the approved budget period. The federal awarding agency is authorized at its discretion to waive prior written approvals to carry forward unobligated balances to subsequent budget period pursuant to ?200.308(e)(3). In accordance with CFR Section 200.458, pre-award costs are those incurred prior to the effective date of the federal award or subaward directly pursuant to the negotiation and in anticipation of the federal award where such costs are necessary for efficient and timely performance of the scope of the work. Such costs are allowable only to the extent they would have been allowable if incurred after the date of the federal award and only with the written approval of the federal awarding agency. In accordance with CFR Section 200.344, the federal awarding agency or pass-through entity will close out the federal award when it determines that all applicable administrative actions and all required work of the federal award have been completed by the nonfederal entity. Per CFR Section 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance. Condition ? During our testing of period of performance, we noted exceptions in the ability of management to support expenditures were incurred and charged to federal programs within the period of performance. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were incurred during the period of performance and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect - The lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with laws, regulations, and the provisions of grant agreements, which could ultimately lead to expenditures not being charged to the major programs in the correct period. Questioned Costs ? $29,459 Context: Assistance Listing Number: 19.016 During our testing of the period of performance compliance requirement for grant award periods that ended during the fiscal year, we sampled 12 expenditures, totaling $292,901, for the Iraq Assistance Program and noted one item amounting to $28,766 did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Additionally, during our testing of the period of performance compliance requirement for grant costs incurred throughout the year, we sampled 40 expenditures, totaling $11,811, for the Iraq Assistance Programs and noted that four items, totaling $672, did not have proper documentation for the allocation of the expenditure. Assistance Listing Number: 19.518 During our testing of the period of performance compliance requirement for grant award periods that started and ended during the fiscal year, we sampled 81 expenditures, totaling $15,252, for the Overseas Refugee Assistance Program for Western Hemisphere and noted two items, totaling $21, did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend that the Organization ensure its policies and procedures ensure that documentation of when the expenditure was incurred and liquidated is maintained and that these policies and procedures are followed on a consistent basis. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with the period of performance compliance requirements. Management through the local offices has already developed a policy to ensure that the period of performance is adhered to.
2022-006: Internal Control Over Compliance and Compliance with Period of Performance Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria ? CFR ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its grants? period of performance process. In accordance with CFR Section 200.403(h), cost must be incurred during the approved budget period. The federal awarding agency is authorized at its discretion to waive prior written approvals to carry forward unobligated balances to subsequent budget period pursuant to ?200.308(e)(3). In accordance with CFR Section 200.458, pre-award costs are those incurred prior to the effective date of the federal award or subaward directly pursuant to the negotiation and in anticipation of the federal award where such costs are necessary for efficient and timely performance of the scope of the work. Such costs are allowable only to the extent they would have been allowable if incurred after the date of the federal award and only with the written approval of the federal awarding agency. In accordance with CFR Section 200.344, the federal awarding agency or pass-through entity will close out the federal award when it determines that all applicable administrative actions and all required work of the federal award have been completed by the nonfederal entity. Per CFR Section 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance. Condition ? During our testing of period of performance, we noted exceptions where expenditures were incurred outside of the grant?s performance period. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were incurred during the period of performance and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect - The lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with law and regulations and possible loss of funding for the related program. Questioned Costs ? $125 Context: During our testing of the allowable costs/cost principles compliance requirements, we sampled 25 nonpayroll expenditures, totaling $6,365, for the Overseas Refugee Assistance Program for Western Hemisphere and noted that four items, totaling $125, were incurred and paid outside of the grant award period. Repeat Finding - This finding is a repeat finding from prior year. This finding was reported as finding 2021-001 in the 2021 reporting package. Recommendation - We recommend management revisits and considers revising its internal procedures around detecting expenditures incurred outside of the period of performance of the awards. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with the period of performance compliance requirements. Management is emphasizing prompt period closing to ensure that no items are recorded in the wrong period.
Finding 2022-013 – Lack of Internal Controls and Noncompliance with Reporting Requirements Over Federal Grant Coronavirus State and Local Fiscal Recovery Funds PASS-THROUGH GRANTOR: Direct Grant FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Reporting QUESTIONED COSTS: $-0- Condition: The County has not established internal controls to ensure the correct expenditure category is used for reporting payments to the grant administrative contractor. The quarterly reports improperly classified payments totaling $147,883 to a contractor as a Revenue Replacement expense instead of using the Administrative expense category. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with federal compliance requirements. Effect of Condition: This condition could result in noncompliance to grant requirements. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. Management Response: Chairman of the Board of County Commissioners: The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants. Criteria: Accountability and stewardship should be overall goals in management’s accounting of federal funds. Internal controls should be designed to monitor compliance with laws and regulations pertaining to grant contracts. Title 2 CFR § 200.303 Internal Controls (a) reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of theUnited States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (10. Reporting.) reads as follows: All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, you organization needs to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Further, 2 CFR § 200.329 Monitoring and Reporting Program Performance (c)(1) reads as follows: The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance reports as required by the terms and conditions of the Federal award. See also § 200.344. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report.
Finding 2022-014 – Noncompliance with Reporting Requirements Over Federal Grant – Coronavirus State and Local Fiscal Recovery Funds PASS-THROUGH GRANTOR: Direct Grant FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Reporting QUESTIONED COSTS: $0 Condition: The test of 100% of Coronavirus State and Local Fiscal Recovery Funds expenditures reflected that an incorrect classification category was used for contractors. The quarterly reports that were filed listed the contractors as subrecipients. Further, expenditures for federal programs were not adequately reported on the CSLFRF Compliance Reports. Federal expenditures were understated by $221,261. The following misstatements were noted: • The actual expenditures to vendors totaled $161,634 and the County reported $180,710, resulting in an overstatement of $19,076. • The actual expenditures to subrecipients totaled $404,257 and the County reported $403,909, resulting in an understatement of $348. • The actual expenditures paid to county employees for premium pay and employee benefits were $1,300,148 and the County reported $1,060,159, resulting in an understatement of $239,989. Reported Total Expenditures of Federal Awards $ 1,644,812 Add: Expenditures to Subrecipients 348 Add: Expenditures for Premium Pay 239,989 Less: Expenditures to Vendors (19,076) Actual Federal Expenditures of Federal Awards 1,866,073 Reporting Understated by $ 221,261 Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with federal compliance requirements. Effect of Condition: This condition resulted in noncompliance to grant requirements. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. Management Response: Chairman of the Board of County Commissioners: The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants. Criteria: Coronavirus State and Local Fiscal Recovery Funds Guidance on Recipient Compliance and Reporting Responsibilities reads as follows: 10. Reporting. All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, your organization needs to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. See Part 2 of this guidance for a full overview of recipient reporting responsibilities. Further, 2 CFR § 200.329 Monitoring and Reporting Program Performance (c)(1) reads as follows: The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance reports as required by the terms and conditions of the Federal award. See also § 200.344. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report.
2022-033 - Weakness in Controls over Research and Development ProjectCloseouts and Accounting RecordsAward Years: 2021, 2022Award Numbers: 1K01AA024494-01A1, 1R21AA026022-01A1, 1R44DA046300-01, 2R01DK087800-06A1, 2R37AA018282-06, GM104940-17025-HSCNO01, INS151591-2, PO-0000180812, WFUHS 35-101730-117901Compliance Requirement: Period of PerformancePass-Through Entities: Eastern Virginia Medical School, La Jolla Alcohol Research, Inc., Wake Forest University HSCRepeat Finding: Yes (Prior Year Finding No. 2021-006)See Schedule of Findings and Questioned Costs for chart/tableCondition:For the third consecutive year, the Louisiana State University Health Sciences Center in New Orleans (LSUHSC-NO) did not have adequate controls over project closeouts or accounting records for the R&D cluster federal program. We tested a non-statistical sample of 18 R&D projects, plus an additional five projects based on the total transaction amount recorded more than 90 days after the project end date, from a population of 139 projects with end dates between April 1, 2021, and June 30, 2022. Five (27.8%) of the sampled projects and all five of the additional projects included transactions for expenses or correcting entries posted to the project between 120 and 402 days after the project?s period of performance ended. On three of the additional projects, management submitted revised final reports to the grantor, or revised final invoices to the pass-through entity, more than 120 days after the period of performance ended resulting in noncompliance with federal program close-out requirements.Criteria:2 CFR 200.344 requires (a) that the recipient must submit, no later than 120 calendar days (or 90 days for a subrecipient) after the end of the period of performance, all reports required by the terms and conditions of the award, and (b) unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end date of the period of performance.Additionally, LSUHSC-NO?s Sponsored Agreement Closeout Policy requires that completed sponsored agreements with surplus and/or deficit residual balances remaining in the project be certified and transferred to an appropriate, non-sponsored, departmentally-funded account or another sponsored project within 90 days of the project end date. LSUHSC-NO?s Sponsored Projects Accounting Cost Transfer Policy 011019 cautions that cost transfers will not be processed to cover cost overruns, to avoid restrictions by the Sponsor, to use up unspent funds, or for reasons of convenience or broadly-defined ?errors.?Cause:These exceptions occurred because (1) expenses are charged to projects after their closeout period in anticipation of a forthcoming project renewal, extension, or funding increase that may or may not be received; (2) the accounting system, PeopleSoft Commitment Control, allows certain personnel and other expenses to continue to post to projects after the project has ended unless a form, such as a change in source of funds form, is processed to update account coding in the system; (3) projects are not being closed out properly as they end, which includes submitting all required forms for updating accounting records; and (4) project budgets were not adequately monitored to ensure that expenses in the accounting system were charged to the correct project and any errors or budget overruns were identified and addressed in a timely manner.Effect:Untimely project updates in the accounting system increase the risk that expenses will be charged to the wrong project which hinders management?s ability to effectively monitor the budget and may result in budget overruns that would need to be covered with other funding sources, increase the number of corrections required at year end to ensure accurate financial reporting, and may result in noncompliance with federal program requirements.Recommendation:Management should continue to monitor budgets and ensure that budget overruns and errors are identified and corrected in a timely manner. Management should ensure that projects are effectively closed out including processing all required forms and updating the accounting system in a timely manner. Management should consider implementing a system control to prevent costs from being charged to projects in the accounting system beyond the project close out period. Management should also implement controls to exclude costs from its Schedule of Expenditures of Federal Awards until the awards or extensions are approved.Management?s Response and Corrective Action Plan:Management concurred with the finding and provided a corrective action plan (B-46).
2022-033 - Weakness in Controls over Research and Development ProjectCloseouts and Accounting RecordsAward Years: 2021, 2022Award Numbers: 1K01AA024494-01A1, 1R21AA026022-01A1, 1R44DA046300-01, 2R01DK087800-06A1, 2R37AA018282-06, GM104940-17025-HSCNO01, INS151591-2, PO-0000180812, WFUHS 35-101730-117901Compliance Requirement: Period of PerformancePass-Through Entities: Eastern Virginia Medical School, La Jolla Alcohol Research, Inc., Wake Forest University HSCRepeat Finding: Yes (Prior Year Finding No. 2021-006)See Schedule of Findings and Questioned Costs for chart/tableCondition:For the third consecutive year, the Louisiana State University Health Sciences Center in New Orleans (LSUHSC-NO) did not have adequate controls over project closeouts or accounting records for the R&D cluster federal program. We tested a non-statistical sample of 18 R&D projects, plus an additional five projects based on the total transaction amount recorded more than 90 days after the project end date, from a population of 139 projects with end dates between April 1, 2021, and June 30, 2022. Five (27.8%) of the sampled projects and all five of the additional projects included transactions for expenses or correcting entries posted to the project between 120 and 402 days after the project?s period of performance ended. On three of the additional projects, management submitted revised final reports to the grantor, or revised final invoices to the pass-through entity, more than 120 days after the period of performance ended resulting in noncompliance with federal program close-out requirements.Criteria:2 CFR 200.344 requires (a) that the recipient must submit, no later than 120 calendar days (or 90 days for a subrecipient) after the end of the period of performance, all reports required by the terms and conditions of the award, and (b) unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end date of the period of performance.Additionally, LSUHSC-NO?s Sponsored Agreement Closeout Policy requires that completed sponsored agreements with surplus and/or deficit residual balances remaining in the project be certified and transferred to an appropriate, non-sponsored, departmentally-funded account or another sponsored project within 90 days of the project end date. LSUHSC-NO?s Sponsored Projects Accounting Cost Transfer Policy 011019 cautions that cost transfers will not be processed to cover cost overruns, to avoid restrictions by the Sponsor, to use up unspent funds, or for reasons of convenience or broadly-defined ?errors.?Cause:These exceptions occurred because (1) expenses are charged to projects after their closeout period in anticipation of a forthcoming project renewal, extension, or funding increase that may or may not be received; (2) the accounting system, PeopleSoft Commitment Control, allows certain personnel and other expenses to continue to post to projects after the project has ended unless a form, such as a change in source of funds form, is processed to update account coding in the system; (3) projects are not being closed out properly as they end, which includes submitting all required forms for updating accounting records; and (4) project budgets were not adequately monitored to ensure that expenses in the accounting system were charged to the correct project and any errors or budget overruns were identified and addressed in a timely manner.Effect:Untimely project updates in the accounting system increase the risk that expenses will be charged to the wrong project which hinders management?s ability to effectively monitor the budget and may result in budget overruns that would need to be covered with other funding sources, increase the number of corrections required at year end to ensure accurate financial reporting, and may result in noncompliance with federal program requirements.Recommendation:Management should continue to monitor budgets and ensure that budget overruns and errors are identified and corrected in a timely manner. Management should ensure that projects are effectively closed out including processing all required forms and updating the accounting system in a timely manner. Management should consider implementing a system control to prevent costs from being charged to projects in the accounting system beyond the project close out period. Management should also implement controls to exclude costs from its Schedule of Expenditures of Federal Awards until the awards or extensions are approved.Management?s Response and Corrective Action Plan:Management concurred with the finding and provided a corrective action plan (B-46).
2022-033 - Weakness in Controls over Research and Development ProjectCloseouts and Accounting RecordsAward Years: 2021, 2022Award Numbers: 1K01AA024494-01A1, 1R21AA026022-01A1, 1R44DA046300-01, 2R01DK087800-06A1, 2R37AA018282-06, GM104940-17025-HSCNO01, INS151591-2, PO-0000180812, WFUHS 35-101730-117901Compliance Requirement: Period of PerformancePass-Through Entities: Eastern Virginia Medical School, La Jolla Alcohol Research, Inc., Wake Forest University HSCRepeat Finding: Yes (Prior Year Finding No. 2021-006)See Schedule of Findings and Questioned Costs for chart/tableCondition:For the third consecutive year, the Louisiana State University Health Sciences Center in New Orleans (LSUHSC-NO) did not have adequate controls over project closeouts or accounting records for the R&D cluster federal program. We tested a non-statistical sample of 18 R&D projects, plus an additional five projects based on the total transaction amount recorded more than 90 days after the project end date, from a population of 139 projects with end dates between April 1, 2021, and June 30, 2022. Five (27.8%) of the sampled projects and all five of the additional projects included transactions for expenses or correcting entries posted to the project between 120 and 402 days after the project?s period of performance ended. On three of the additional projects, management submitted revised final reports to the grantor, or revised final invoices to the pass-through entity, more than 120 days after the period of performance ended resulting in noncompliance with federal program close-out requirements.Criteria:2 CFR 200.344 requires (a) that the recipient must submit, no later than 120 calendar days (or 90 days for a subrecipient) after the end of the period of performance, all reports required by the terms and conditions of the award, and (b) unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end date of the period of performance.Additionally, LSUHSC-NO?s Sponsored Agreement Closeout Policy requires that completed sponsored agreements with surplus and/or deficit residual balances remaining in the project be certified and transferred to an appropriate, non-sponsored, departmentally-funded account or another sponsored project within 90 days of the project end date. LSUHSC-NO?s Sponsored Projects Accounting Cost Transfer Policy 011019 cautions that cost transfers will not be processed to cover cost overruns, to avoid restrictions by the Sponsor, to use up unspent funds, or for reasons of convenience or broadly-defined ?errors.?Cause:These exceptions occurred because (1) expenses are charged to projects after their closeout period in anticipation of a forthcoming project renewal, extension, or funding increase that may or may not be received; (2) the accounting system, PeopleSoft Commitment Control, allows certain personnel and other expenses to continue to post to projects after the project has ended unless a form, such as a change in source of funds form, is processed to update account coding in the system; (3) projects are not being closed out properly as they end, which includes submitting all required forms for updating accounting records; and (4) project budgets were not adequately monitored to ensure that expenses in the accounting system were charged to the correct project and any errors or budget overruns were identified and addressed in a timely manner.Effect:Untimely project updates in the accounting system increase the risk that expenses will be charged to the wrong project which hinders management?s ability to effectively monitor the budget and may result in budget overruns that would need to be covered with other funding sources, increase the number of corrections required at year end to ensure accurate financial reporting, and may result in noncompliance with federal program requirements.Recommendation:Management should continue to monitor budgets and ensure that budget overruns and errors are identified and corrected in a timely manner. Management should ensure that projects are effectively closed out including processing all required forms and updating the accounting system in a timely manner. Management should consider implementing a system control to prevent costs from being charged to projects in the accounting system beyond the project close out period. Management should also implement controls to exclude costs from its Schedule of Expenditures of Federal Awards until the awards or extensions are approved.Management?s Response and Corrective Action Plan:Management concurred with the finding and provided a corrective action plan (B-46).
2022-033 - Weakness in Controls over Research and Development ProjectCloseouts and Accounting RecordsAward Years: 2021, 2022Award Numbers: 1K01AA024494-01A1, 1R21AA026022-01A1, 1R44DA046300-01, 2R01DK087800-06A1, 2R37AA018282-06, GM104940-17025-HSCNO01, INS151591-2, PO-0000180812, WFUHS 35-101730-117901Compliance Requirement: Period of PerformancePass-Through Entities: Eastern Virginia Medical School, La Jolla Alcohol Research, Inc., Wake Forest University HSCRepeat Finding: Yes (Prior Year Finding No. 2021-006)See Schedule of Findings and Questioned Costs for chart/tableCondition:For the third consecutive year, the Louisiana State University Health Sciences Center in New Orleans (LSUHSC-NO) did not have adequate controls over project closeouts or accounting records for the R&D cluster federal program. We tested a non-statistical sample of 18 R&D projects, plus an additional five projects based on the total transaction amount recorded more than 90 days after the project end date, from a population of 139 projects with end dates between April 1, 2021, and June 30, 2022. Five (27.8%) of the sampled projects and all five of the additional projects included transactions for expenses or correcting entries posted to the project between 120 and 402 days after the project?s period of performance ended. On three of the additional projects, management submitted revised final reports to the grantor, or revised final invoices to the pass-through entity, more than 120 days after the period of performance ended resulting in noncompliance with federal program close-out requirements.Criteria:2 CFR 200.344 requires (a) that the recipient must submit, no later than 120 calendar days (or 90 days for a subrecipient) after the end of the period of performance, all reports required by the terms and conditions of the award, and (b) unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end date of the period of performance.Additionally, LSUHSC-NO?s Sponsored Agreement Closeout Policy requires that completed sponsored agreements with surplus and/or deficit residual balances remaining in the project be certified and transferred to an appropriate, non-sponsored, departmentally-funded account or another sponsored project within 90 days of the project end date. LSUHSC-NO?s Sponsored Projects Accounting Cost Transfer Policy 011019 cautions that cost transfers will not be processed to cover cost overruns, to avoid restrictions by the Sponsor, to use up unspent funds, or for reasons of convenience or broadly-defined ?errors.?Cause:These exceptions occurred because (1) expenses are charged to projects after their closeout period in anticipation of a forthcoming project renewal, extension, or funding increase that may or may not be received; (2) the accounting system, PeopleSoft Commitment Control, allows certain personnel and other expenses to continue to post to projects after the project has ended unless a form, such as a change in source of funds form, is processed to update account coding in the system; (3) projects are not being closed out properly as they end, which includes submitting all required forms for updating accounting records; and (4) project budgets were not adequately monitored to ensure that expenses in the accounting system were charged to the correct project and any errors or budget overruns were identified and addressed in a timely manner.Effect:Untimely project updates in the accounting system increase the risk that expenses will be charged to the wrong project which hinders management?s ability to effectively monitor the budget and may result in budget overruns that would need to be covered with other funding sources, increase the number of corrections required at year end to ensure accurate financial reporting, and may result in noncompliance with federal program requirements.Recommendation:Management should continue to monitor budgets and ensure that budget overruns and errors are identified and corrected in a timely manner. Management should ensure that projects are effectively closed out including processing all required forms and updating the accounting system in a timely manner. Management should consider implementing a system control to prevent costs from being charged to projects in the accounting system beyond the project close out period. Management should also implement controls to exclude costs from its Schedule of Expenditures of Federal Awards until the awards or extensions are approved.Management?s Response and Corrective Action Plan:Management concurred with the finding and provided a corrective action plan (B-46).
2022-033 - Weakness in Controls over Research and Development ProjectCloseouts and Accounting RecordsAward Years: 2021, 2022Award Numbers: 1K01AA024494-01A1, 1R21AA026022-01A1, 1R44DA046300-01, 2R01DK087800-06A1, 2R37AA018282-06, GM104940-17025-HSCNO01, INS151591-2, PO-0000180812, WFUHS 35-101730-117901Compliance Requirement: Period of PerformancePass-Through Entities: Eastern Virginia Medical School, La Jolla Alcohol Research, Inc., Wake Forest University HSCRepeat Finding: Yes (Prior Year Finding No. 2021-006)See Schedule of Findings and Questioned Costs for chart/tableCondition:For the third consecutive year, the Louisiana State University Health Sciences Center in New Orleans (LSUHSC-NO) did not have adequate controls over project closeouts or accounting records for the R&D cluster federal program. We tested a non-statistical sample of 18 R&D projects, plus an additional five projects based on the total transaction amount recorded more than 90 days after the project end date, from a population of 139 projects with end dates between April 1, 2021, and June 30, 2022. Five (27.8%) of the sampled projects and all five of the additional projects included transactions for expenses or correcting entries posted to the project between 120 and 402 days after the project?s period of performance ended. On three of the additional projects, management submitted revised final reports to the grantor, or revised final invoices to the pass-through entity, more than 120 days after the period of performance ended resulting in noncompliance with federal program close-out requirements.Criteria:2 CFR 200.344 requires (a) that the recipient must submit, no later than 120 calendar days (or 90 days for a subrecipient) after the end of the period of performance, all reports required by the terms and conditions of the award, and (b) unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end date of the period of performance.Additionally, LSUHSC-NO?s Sponsored Agreement Closeout Policy requires that completed sponsored agreements with surplus and/or deficit residual balances remaining in the project be certified and transferred to an appropriate, non-sponsored, departmentally-funded account or another sponsored project within 90 days of the project end date. LSUHSC-NO?s Sponsored Projects Accounting Cost Transfer Policy 011019 cautions that cost transfers will not be processed to cover cost overruns, to avoid restrictions by the Sponsor, to use up unspent funds, or for reasons of convenience or broadly-defined ?errors.?Cause:These exceptions occurred because (1) expenses are charged to projects after their closeout period in anticipation of a forthcoming project renewal, extension, or funding increase that may or may not be received; (2) the accounting system, PeopleSoft Commitment Control, allows certain personnel and other expenses to continue to post to projects after the project has ended unless a form, such as a change in source of funds form, is processed to update account coding in the system; (3) projects are not being closed out properly as they end, which includes submitting all required forms for updating accounting records; and (4) project budgets were not adequately monitored to ensure that expenses in the accounting system were charged to the correct project and any errors or budget overruns were identified and addressed in a timely manner.Effect:Untimely project updates in the accounting system increase the risk that expenses will be charged to the wrong project which hinders management?s ability to effectively monitor the budget and may result in budget overruns that would need to be covered with other funding sources, increase the number of corrections required at year end to ensure accurate financial reporting, and may result in noncompliance with federal program requirements.Recommendation:Management should continue to monitor budgets and ensure that budget overruns and errors are identified and corrected in a timely manner. Management should ensure that projects are effectively closed out including processing all required forms and updating the accounting system in a timely manner. Management should consider implementing a system control to prevent costs from being charged to projects in the accounting system beyond the project close out period. Management should also implement controls to exclude costs from its Schedule of Expenditures of Federal Awards until the awards or extensions are approved.Management?s Response and Corrective Action Plan:Management concurred with the finding and provided a corrective action plan (B-46).
2022-033 - Weakness in Controls over Research and Development ProjectCloseouts and Accounting RecordsAward Years: 2021, 2022Award Numbers: 1K01AA024494-01A1, 1R21AA026022-01A1, 1R44DA046300-01, 2R01DK087800-06A1, 2R37AA018282-06, GM104940-17025-HSCNO01, INS151591-2, PO-0000180812, WFUHS 35-101730-117901Compliance Requirement: Period of PerformancePass-Through Entities: Eastern Virginia Medical School, La Jolla Alcohol Research, Inc., Wake Forest University HSCRepeat Finding: Yes (Prior Year Finding No. 2021-006)See Schedule of Findings and Questioned Costs for chart/tableCondition:For the third consecutive year, the Louisiana State University Health Sciences Center in New Orleans (LSUHSC-NO) did not have adequate controls over project closeouts or accounting records for the R&D cluster federal program. We tested a non-statistical sample of 18 R&D projects, plus an additional five projects based on the total transaction amount recorded more than 90 days after the project end date, from a population of 139 projects with end dates between April 1, 2021, and June 30, 2022. Five (27.8%) of the sampled projects and all five of the additional projects included transactions for expenses or correcting entries posted to the project between 120 and 402 days after the project?s period of performance ended. On three of the additional projects, management submitted revised final reports to the grantor, or revised final invoices to the pass-through entity, more than 120 days after the period of performance ended resulting in noncompliance with federal program close-out requirements.Criteria:2 CFR 200.344 requires (a) that the recipient must submit, no later than 120 calendar days (or 90 days for a subrecipient) after the end of the period of performance, all reports required by the terms and conditions of the award, and (b) unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end date of the period of performance.Additionally, LSUHSC-NO?s Sponsored Agreement Closeout Policy requires that completed sponsored agreements with surplus and/or deficit residual balances remaining in the project be certified and transferred to an appropriate, non-sponsored, departmentally-funded account or another sponsored project within 90 days of the project end date. LSUHSC-NO?s Sponsored Projects Accounting Cost Transfer Policy 011019 cautions that cost transfers will not be processed to cover cost overruns, to avoid restrictions by the Sponsor, to use up unspent funds, or for reasons of convenience or broadly-defined ?errors.?Cause:These exceptions occurred because (1) expenses are charged to projects after their closeout period in anticipation of a forthcoming project renewal, extension, or funding increase that may or may not be received; (2) the accounting system, PeopleSoft Commitment Control, allows certain personnel and other expenses to continue to post to projects after the project has ended unless a form, such as a change in source of funds form, is processed to update account coding in the system; (3) projects are not being closed out properly as they end, which includes submitting all required forms for updating accounting records; and (4) project budgets were not adequately monitored to ensure that expenses in the accounting system were charged to the correct project and any errors or budget overruns were identified and addressed in a timely manner.Effect:Untimely project updates in the accounting system increase the risk that expenses will be charged to the wrong project which hinders management?s ability to effectively monitor the budget and may result in budget overruns that would need to be covered with other funding sources, increase the number of corrections required at year end to ensure accurate financial reporting, and may result in noncompliance with federal program requirements.Recommendation:Management should continue to monitor budgets and ensure that budget overruns and errors are identified and corrected in a timely manner. Management should ensure that projects are effectively closed out including processing all required forms and updating the accounting system in a timely manner. Management should consider implementing a system control to prevent costs from being charged to projects in the accounting system beyond the project close out period. Management should also implement controls to exclude costs from its Schedule of Expenditures of Federal Awards until the awards or extensions are approved.Management?s Response and Corrective Action Plan:Management concurred with the finding and provided a corrective action plan (B-46).
2022-033 - Weakness in Controls over Research and Development ProjectCloseouts and Accounting RecordsAward Years: 2021, 2022Award Numbers: 1K01AA024494-01A1, 1R21AA026022-01A1, 1R44DA046300-01, 2R01DK087800-06A1, 2R37AA018282-06, GM104940-17025-HSCNO01, INS151591-2, PO-0000180812, WFUHS 35-101730-117901Compliance Requirement: Period of PerformancePass-Through Entities: Eastern Virginia Medical School, La Jolla Alcohol Research, Inc., Wake Forest University HSCRepeat Finding: Yes (Prior Year Finding No. 2021-006)See Schedule of Findings and Questioned Costs for chart/tableCondition:For the third consecutive year, the Louisiana State University Health Sciences Center in New Orleans (LSUHSC-NO) did not have adequate controls over project closeouts or accounting records for the R&D cluster federal program. We tested a non-statistical sample of 18 R&D projects, plus an additional five projects based on the total transaction amount recorded more than 90 days after the project end date, from a population of 139 projects with end dates between April 1, 2021, and June 30, 2022. Five (27.8%) of the sampled projects and all five of the additional projects included transactions for expenses or correcting entries posted to the project between 120 and 402 days after the project?s period of performance ended. On three of the additional projects, management submitted revised final reports to the grantor, or revised final invoices to the pass-through entity, more than 120 days after the period of performance ended resulting in noncompliance with federal program close-out requirements.Criteria:2 CFR 200.344 requires (a) that the recipient must submit, no later than 120 calendar days (or 90 days for a subrecipient) after the end of the period of performance, all reports required by the terms and conditions of the award, and (b) unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end date of the period of performance.Additionally, LSUHSC-NO?s Sponsored Agreement Closeout Policy requires that completed sponsored agreements with surplus and/or deficit residual balances remaining in the project be certified and transferred to an appropriate, non-sponsored, departmentally-funded account or another sponsored project within 90 days of the project end date. LSUHSC-NO?s Sponsored Projects Accounting Cost Transfer Policy 011019 cautions that cost transfers will not be processed to cover cost overruns, to avoid restrictions by the Sponsor, to use up unspent funds, or for reasons of convenience or broadly-defined ?errors.?Cause:These exceptions occurred because (1) expenses are charged to projects after their closeout period in anticipation of a forthcoming project renewal, extension, or funding increase that may or may not be received; (2) the accounting system, PeopleSoft Commitment Control, allows certain personnel and other expenses to continue to post to projects after the project has ended unless a form, such as a change in source of funds form, is processed to update account coding in the system; (3) projects are not being closed out properly as they end, which includes submitting all required forms for updating accounting records; and (4) project budgets were not adequately monitored to ensure that expenses in the accounting system were charged to the correct project and any errors or budget overruns were identified and addressed in a timely manner.Effect:Untimely project updates in the accounting system increase the risk that expenses will be charged to the wrong project which hinders management?s ability to effectively monitor the budget and may result in budget overruns that would need to be covered with other funding sources, increase the number of corrections required at year end to ensure accurate financial reporting, and may result in noncompliance with federal program requirements.Recommendation:Management should continue to monitor budgets and ensure that budget overruns and errors are identified and corrected in a timely manner. Management should ensure that projects are effectively closed out including processing all required forms and updating the accounting system in a timely manner. Management should consider implementing a system control to prevent costs from being charged to projects in the accounting system beyond the project close out period. Management should also implement controls to exclude costs from its Schedule of Expenditures of Federal Awards until the awards or extensions are approved.Management?s Response and Corrective Action Plan:Management concurred with the finding and provided a corrective action plan (B-46).
2022-033 - Weakness in Controls over Research and Development ProjectCloseouts and Accounting RecordsAward Years: 2021, 2022Award Numbers: 1K01AA024494-01A1, 1R21AA026022-01A1, 1R44DA046300-01, 2R01DK087800-06A1, 2R37AA018282-06, GM104940-17025-HSCNO01, INS151591-2, PO-0000180812, WFUHS 35-101730-117901Compliance Requirement: Period of PerformancePass-Through Entities: Eastern Virginia Medical School, La Jolla Alcohol Research, Inc., Wake Forest University HSCRepeat Finding: Yes (Prior Year Finding No. 2021-006)See Schedule of Findings and Questioned Costs for chart/tableCondition:For the third consecutive year, the Louisiana State University Health Sciences Center in New Orleans (LSUHSC-NO) did not have adequate controls over project closeouts or accounting records for the R&D cluster federal program. We tested a non-statistical sample of 18 R&D projects, plus an additional five projects based on the total transaction amount recorded more than 90 days after the project end date, from a population of 139 projects with end dates between April 1, 2021, and June 30, 2022. Five (27.8%) of the sampled projects and all five of the additional projects included transactions for expenses or correcting entries posted to the project between 120 and 402 days after the project?s period of performance ended. On three of the additional projects, management submitted revised final reports to the grantor, or revised final invoices to the pass-through entity, more than 120 days after the period of performance ended resulting in noncompliance with federal program close-out requirements.Criteria:2 CFR 200.344 requires (a) that the recipient must submit, no later than 120 calendar days (or 90 days for a subrecipient) after the end of the period of performance, all reports required by the terms and conditions of the award, and (b) unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end date of the period of performance.Additionally, LSUHSC-NO?s Sponsored Agreement Closeout Policy requires that completed sponsored agreements with surplus and/or deficit residual balances remaining in the project be certified and transferred to an appropriate, non-sponsored, departmentally-funded account or another sponsored project within 90 days of the project end date. LSUHSC-NO?s Sponsored Projects Accounting Cost Transfer Policy 011019 cautions that cost transfers will not be processed to cover cost overruns, to avoid restrictions by the Sponsor, to use up unspent funds, or for reasons of convenience or broadly-defined ?errors.?Cause:These exceptions occurred because (1) expenses are charged to projects after their closeout period in anticipation of a forthcoming project renewal, extension, or funding increase that may or may not be received; (2) the accounting system, PeopleSoft Commitment Control, allows certain personnel and other expenses to continue to post to projects after the project has ended unless a form, such as a change in source of funds form, is processed to update account coding in the system; (3) projects are not being closed out properly as they end, which includes submitting all required forms for updating accounting records; and (4) project budgets were not adequately monitored to ensure that expenses in the accounting system were charged to the correct project and any errors or budget overruns were identified and addressed in a timely manner.Effect:Untimely project updates in the accounting system increase the risk that expenses will be charged to the wrong project which hinders management?s ability to effectively monitor the budget and may result in budget overruns that would need to be covered with other funding sources, increase the number of corrections required at year end to ensure accurate financial reporting, and may result in noncompliance with federal program requirements.Recommendation:Management should continue to monitor budgets and ensure that budget overruns and errors are identified and corrected in a timely manner. Management should ensure that projects are effectively closed out including processing all required forms and updating the accounting system in a timely manner. Management should consider implementing a system control to prevent costs from being charged to projects in the accounting system beyond the project close out period. Management should also implement controls to exclude costs from its Schedule of Expenditures of Federal Awards until the awards or extensions are approved.Management?s Response and Corrective Action Plan:Management concurred with the finding and provided a corrective action plan (B-46).
2022-033 - Weakness in Controls over Research and Development ProjectCloseouts and Accounting RecordsAward Years: 2021, 2022Award Numbers: 1K01AA024494-01A1, 1R21AA026022-01A1, 1R44DA046300-01, 2R01DK087800-06A1, 2R37AA018282-06, GM104940-17025-HSCNO01, INS151591-2, PO-0000180812, WFUHS 35-101730-117901Compliance Requirement: Period of PerformancePass-Through Entities: Eastern Virginia Medical School, La Jolla Alcohol Research, Inc., Wake Forest University HSCRepeat Finding: Yes (Prior Year Finding No. 2021-006)See Schedule of Findings and Questioned Costs for chart/tableCondition:For the third consecutive year, the Louisiana State University Health Sciences Center in New Orleans (LSUHSC-NO) did not have adequate controls over project closeouts or accounting records for the R&D cluster federal program. We tested a non-statistical sample of 18 R&D projects, plus an additional five projects based on the total transaction amount recorded more than 90 days after the project end date, from a population of 139 projects with end dates between April 1, 2021, and June 30, 2022. Five (27.8%) of the sampled projects and all five of the additional projects included transactions for expenses or correcting entries posted to the project between 120 and 402 days after the project?s period of performance ended. On three of the additional projects, management submitted revised final reports to the grantor, or revised final invoices to the pass-through entity, more than 120 days after the period of performance ended resulting in noncompliance with federal program close-out requirements.Criteria:2 CFR 200.344 requires (a) that the recipient must submit, no later than 120 calendar days (or 90 days for a subrecipient) after the end of the period of performance, all reports required by the terms and conditions of the award, and (b) unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end date of the period of performance.Additionally, LSUHSC-NO?s Sponsored Agreement Closeout Policy requires that completed sponsored agreements with surplus and/or deficit residual balances remaining in the project be certified and transferred to an appropriate, non-sponsored, departmentally-funded account or another sponsored project within 90 days of the project end date. LSUHSC-NO?s Sponsored Projects Accounting Cost Transfer Policy 011019 cautions that cost transfers will not be processed to cover cost overruns, to avoid restrictions by the Sponsor, to use up unspent funds, or for reasons of convenience or broadly-defined ?errors.?Cause:These exceptions occurred because (1) expenses are charged to projects after their closeout period in anticipation of a forthcoming project renewal, extension, or funding increase that may or may not be received; (2) the accounting system, PeopleSoft Commitment Control, allows certain personnel and other expenses to continue to post to projects after the project has ended unless a form, such as a change in source of funds form, is processed to update account coding in the system; (3) projects are not being closed out properly as they end, which includes submitting all required forms for updating accounting records; and (4) project budgets were not adequately monitored to ensure that expenses in the accounting system were charged to the correct project and any errors or budget overruns were identified and addressed in a timely manner.Effect:Untimely project updates in the accounting system increase the risk that expenses will be charged to the wrong project which hinders management?s ability to effectively monitor the budget and may result in budget overruns that would need to be covered with other funding sources, increase the number of corrections required at year end to ensure accurate financial reporting, and may result in noncompliance with federal program requirements.Recommendation:Management should continue to monitor budgets and ensure that budget overruns and errors are identified and corrected in a timely manner. Management should ensure that projects are effectively closed out including processing all required forms and updating the accounting system in a timely manner. Management should consider implementing a system control to prevent costs from being charged to projects in the accounting system beyond the project close out period. Management should also implement controls to exclude costs from its Schedule of Expenditures of Federal Awards until the awards or extensions are approved.Management?s Response and Corrective Action Plan:Management concurred with the finding and provided a corrective action plan (B-46).
Condition: During the test of 100% of expenditures, two (2) expenditures totaling $570,080, for the Coronavirus State and Local Fiscal Recovery Funds, the following noncompliance with the Reporting compliance requirement was noted: • The interim and the 3rd quarter reports were not submitted. • The 2nd quarter report was not timely submitted. • The County improperly reported a vendor as a subrecipient instead of as a vendor relationship. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are properly reported in accordance with federal compliance requirements. Effect of Condition: This condition resulted in noncompliance with federal grant guidelines. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. Management Response: Board of County Commissioners: The Board of County Commissioners is responsible for the overall fiscal concerns of the county. See OKLA. STAT. Title 19, § 345. The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. These policies and procedures will be designed to identify requirements for recipients and sub-recipients of grants, ensure accurate equipment and real property management, procurement, recipient and subrecipient monitoring and reporting. Further, policies will ensure a proper understanding of all grant requirements and compliance of the same. To assist in this process, the Board of County Commissioners engaged a third-party administrator to oversee the grant process, including application, eligibility, review, requirements, contracting, recipient tracking and oversight, and documentation and reporting. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration. Criteria: Accountability and stewardship should be overall goals in management’s accounting of federal funds. Internal controls should be designed to monitor compliance with laws and regulations pertaining to grant contracts. Title 2 CFR § 200.303(a) Internal Controls, reads as follows: The non-federal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework, “issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (10. Reporting) reads as follows: All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlines in Part 2 of this guidance. Expenditures may be reported on a cash of accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, your organization needs to establish internal controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Further, 2 CFR 200.329-Monitoring and reporting Program Performance (c)(1) reads as follows: (c)(1) The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar gays after the period of performance end date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance reports as required by the terms and conditions of the Federal award. See also §200.344. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report.
U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the fiscal year were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The Town is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the fiscal year were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The Town is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the fiscal year were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The Town is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.