Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Program: ACTIVITIES ALLOWED OR UNALLOWED Criteria: The U.S. Department of Education provided additional guidance to grantees on ESSER funded activities that continue beyond the obligation and liquidation periods. A grantee or subgrantee must obligate ESSER funds within the period of availability and must liquidate those obligations within 120 days of the end of the period of availability (2 CFR section 200.344 (b)) (or within the approved period for a liquidation extension). The guidance states that under limited circumstances where a grantee or subgrantee timely obligates the ESSER funds, it may be allowable for ESSER funded activities to continue for a reasonable time beyond the obligation and liquidation period. Because ESSER is a State-administered program, the SEA or Governor determine whether activities extending past the liquidation period are allowable under the circumstances. The guidance also states that under no circumstances may services extend beyond the date on which funds revert to the U.S. Department of Treasury, which occurs four years after the obligation deadline. Condition: During our test of compliance with activities allowed and unallowed, we noted that the School District entered into multi-year contracts for software licenses and consumable supplies during the period of availability and paid for the entirety of the softwares licenses and consumable supplies within the liquidation period. The contracts were included in the ARP ESSER grant budget approved by the RI Department of Education. The multi-year contracts are for 6 years and extend beyond the liquidation period of September 30, 2024. The contracts extend to June 30, 2029, which is beyond the date on which funds revert to the U.S. Department of Treasury. Cause: The School District was unaware that the services could not extend past fours years of the liquidation date of September 30, 2024, which is September 30, 2028. Effect: The School District entered into contracts using ARP funds, a portion of which are considered an unallowed activity due to the fact that the services provided extend beyond the period allowed. Questioned Costs: $29,348 Recommendation: We recommend that in addition to receiving approval by the RI Department of Education of grant funded projects that the School District staff responsible for approving the grant projects review federal laws and regulations and guidance specific to the grant programs. Views of Responsible Officials: In our commitment to due diligence and adherence to compliance requirements for the expenditure of funds from a federal grant, the School District contacted the responsible representatives at the Rhode Island Department of Education (RIDE) to seek guidance on establishing a multi-year contract for curriculum materials. The budget description submitted to RIDE for approval indicated that the School District adopted the Bridge program in March 2024. It detailed that the associated expenses would be incurred under a six-year contract covering licenses and consumables, classified as High-Quality Curriculum Materials. This expense received both programmatic and budgetary approval from the Rhode Island Department of Education. Moving forward, the School District will request all supporting documentation to ensure compliance to the laws and regulations governing any federal or state grant.
U.S. DEPARTMENT OF EDUCATION PASSED THROUGH THE ARKANSAS DEPARTMENT OF EDUCATION COVID-19 AMERICAN RESCUE PLAN - ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF FUND - AL# 84.425U PASS-THROUGH NUMBER 3105 AUDIT PERIOD - YEAR ENDED JUNE 30, 2024 Criteria or specific requirement: Office of Management and Budget (OMB) 2 CFR section 200.502 states the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. OMB 2 CFR section 200.344(b) requires that 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 as specified in the terms and conditions of the federal award unless the federal awarding agency or pass-through entity authorizes an extension. American Rescue Plan - Elementary and Secondary Emergency Relief Funds must be obligated by September 30, 2024 and liquidated by January 28, 2025. Condition: The District issued two checks totaling $282,435 for the purchase of two buses on June 25, 2024 and held the checks awaiting delivery of the buses. The District reported the expenditures prior to being incurred and received federal reimbursement from the Education Stabilization Fund of $282,435. The District took possession of the buses and gave the payments to the vendor on February 5, 2025. The federal funds were not obligated or liquidated during the Education Stabilization Fund's period of performance. Cause: Lack of management oversight and adherence to program requirements. Effect or potential effect: $282,435 was reimbursed without an expenditure being incurred. Questioned costs: $282,435 Context: Identified during review of bank reconciliations in the financial statement audit. The program was not audited as a major federal program. Identification as a repeat finding: No Recommendation: The District should contact the Arkansas Division of Elementary and Secondary Education for guidance regarding this matter. Views of responsible officials: DESE has informed us that if this situation ever comes up in the future, asking for a federal extension if buses were not going to be delivered in a timely manner (by January 10, 2025). The manufacturer assured us that the buses would be delivered by November 4, 2024 so we didn’t ask for the extension. In the future, we will wait until buses are on site to write checks. We do not anticipate any ESSER ARP money to be issued in the near future.
CONDITION: During my review of the District’s compliance with the laws and regulations related to filing its federal grant program Final Expenditure Reports (FER), I noted that the School District did not file the Final Expenditure Report for the ARP ESSER, ARP ESSER Learning Loss, ARP ESSER Summer Enrichment, and ARP ESSER Afterschool grant programs until November of 2024. The report was required to be filed with the Pennsylvania Department of Education (PDE) no later than 90 days after the end date of the grant period, or within 30 days of expending all grant funding. This is a repeat Finding (2023-001) from the prior fiscal year. CRITERIA: The Department of Education requires the completion and submission of a ‘Final Expenditure Report’ (FER) within 30 days of expending all grant funding. In addition, Section 2 CFR 200.344 of the Uniform Guidance requires the submission of financial reports no later than 90 calendar days after the end date of the grant period for performance. EFFECT: The District is not in compliance with the financial reporting requirements for timely submission of a ‘final expenditure report’ (FER) for its ARP ESSER, ARP ESSER Learning Loss, ARP ESSER Summer Enrichment, and ARP ESSER Afterschool grant programs in accordance with PDE policy and Section 2 CFR 200.344 of the Uniform Guidance. QUESTIONED COST: None CAUSE: As a result of staff turnover, the School District inadvertently did not complete and file the Final Expenditure Reports with PDE in a timely manner. RECOMMENDATION: I recommend that the District develop fiscal procedures to ensure that ‘Final Expenditure Reports’ for future fiscal years are completed and filed in a timely manner based on supporting financial information obtained from the District’s business office, in order to 1) comply with PDE reporting requirements for the District’s applicable federal programs, and 2) to avoid any future sanctions or withholding of grant monies from PDE as a result of not filing these reports in a timely manner. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: During my review of the District’s compliance with the laws and regulations related to filing its federal grant program Final Expenditure Reports (FER), I noted that the School District did not file the Final Expenditure Report for the ARP ESSER, ARP ESSER Learning Loss, ARP ESSER Summer Enrichment, and ARP ESSER Afterschool grant programs until November of 2024. The report was required to be filed with the Pennsylvania Department of Education (PDE) no later than 90 days after the end date of the grant period, or within 30 days of expending all grant funding. This is a repeat Finding (2023-001) from the prior fiscal year. CRITERIA: The Department of Education requires the completion and submission of a ‘Final Expenditure Report’ (FER) within 30 days of expending all grant funding. In addition, Section 2 CFR 200.344 of the Uniform Guidance requires the submission of financial reports no later than 90 calendar days after the end date of the grant period for performance. EFFECT: The District is not in compliance with the financial reporting requirements for timely submission of a ‘final expenditure report’ (FER) for its ARP ESSER, ARP ESSER Learning Loss, ARP ESSER Summer Enrichment, and ARP ESSER Afterschool grant programs in accordance with PDE policy and Section 2 CFR 200.344 of the Uniform Guidance. QUESTIONED COST: None CAUSE: As a result of staff turnover, the School District inadvertently did not complete and file the Final Expenditure Reports with PDE in a timely manner. RECOMMENDATION: I recommend that the District develop fiscal procedures to ensure that ‘Final Expenditure Reports’ for future fiscal years are completed and filed in a timely manner based on supporting financial information obtained from the District’s business office, in order to 1) comply with PDE reporting requirements for the District’s applicable federal programs, and 2) to avoid any future sanctions or withholding of grant monies from PDE as a result of not filing these reports in a timely manner. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: During my review of the District’s compliance with the laws and regulations related to filing its federal grant program Final Expenditure Reports (FER), I noted that the School District did not file the Final Expenditure Report for the ARP ESSER, ARP ESSER Learning Loss, ARP ESSER Summer Enrichment, and ARP ESSER Afterschool grant programs until November of 2024. The report was required to be filed with the Pennsylvania Department of Education (PDE) no later than 90 days after the end date of the grant period, or within 30 days of expending all grant funding. This is a repeat Finding (2023-001) from the prior fiscal year. CRITERIA: The Department of Education requires the completion and submission of a ‘Final Expenditure Report’ (FER) within 30 days of expending all grant funding. In addition, Section 2 CFR 200.344 of the Uniform Guidance requires the submission of financial reports no later than 90 calendar days after the end date of the grant period for performance. EFFECT: The District is not in compliance with the financial reporting requirements for timely submission of a ‘final expenditure report’ (FER) for its ARP ESSER, ARP ESSER Learning Loss, ARP ESSER Summer Enrichment, and ARP ESSER Afterschool grant programs in accordance with PDE policy and Section 2 CFR 200.344 of the Uniform Guidance. QUESTIONED COST: None CAUSE: As a result of staff turnover, the School District inadvertently did not complete and file the Final Expenditure Reports with PDE in a timely manner. RECOMMENDATION: I recommend that the District develop fiscal procedures to ensure that ‘Final Expenditure Reports’ for future fiscal years are completed and filed in a timely manner based on supporting financial information obtained from the District’s business office, in order to 1) comply with PDE reporting requirements for the District’s applicable federal programs, and 2) to avoid any future sanctions or withholding of grant monies from PDE as a result of not filing these reports in a timely manner. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: During my review of the District’s compliance with the laws and regulations related to filing its federal grant program Final Expenditure Reports (FER), I noted that the School District did not file the Final Expenditure Report for the ARP ESSER, ARP ESSER Learning Loss, ARP ESSER Summer Enrichment, and ARP ESSER Afterschool grant programs until November of 2024. The report was required to be filed with the Pennsylvania Department of Education (PDE) no later than 90 days after the end date of the grant period, or within 30 days of expending all grant funding. This is a repeat Finding (2023-001) from the prior fiscal year. CRITERIA: The Department of Education requires the completion and submission of a ‘Final Expenditure Report’ (FER) within 30 days of expending all grant funding. In addition, Section 2 CFR 200.344 of the Uniform Guidance requires the submission of financial reports no later than 90 calendar days after the end date of the grant period for performance. EFFECT: The District is not in compliance with the financial reporting requirements for timely submission of a ‘final expenditure report’ (FER) for its ARP ESSER, ARP ESSER Learning Loss, ARP ESSER Summer Enrichment, and ARP ESSER Afterschool grant programs in accordance with PDE policy and Section 2 CFR 200.344 of the Uniform Guidance. QUESTIONED COST: None CAUSE: As a result of staff turnover, the School District inadvertently did not complete and file the Final Expenditure Reports with PDE in a timely manner. RECOMMENDATION: I recommend that the District develop fiscal procedures to ensure that ‘Final Expenditure Reports’ for future fiscal years are completed and filed in a timely manner based on supporting financial information obtained from the District’s business office, in order to 1) comply with PDE reporting requirements for the District’s applicable federal programs, and 2) to avoid any future sanctions or withholding of grant monies from PDE as a result of not filing these reports in a timely manner. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: During my review of the District’s compliance with the laws and regulations related to filing its federal grant program Final Expenditure Reports (FER), I noted that the School District did not file the Final Expenditure Report for the ARP ESSER, ARP ESSER Learning Loss, ARP ESSER Summer Enrichment, and ARP ESSER Afterschool grant programs until November of 2024. The report was required to be filed with the Pennsylvania Department of Education (PDE) no later than 90 days after the end date of the grant period, or within 30 days of expending all grant funding. This is a repeat Finding (2023-001) from the prior fiscal year. CRITERIA: The Department of Education requires the completion and submission of a ‘Final Expenditure Report’ (FER) within 30 days of expending all grant funding. In addition, Section 2 CFR 200.344 of the Uniform Guidance requires the submission of financial reports no later than 90 calendar days after the end date of the grant period for performance. EFFECT: The District is not in compliance with the financial reporting requirements for timely submission of a ‘final expenditure report’ (FER) for its ARP ESSER, ARP ESSER Learning Loss, ARP ESSER Summer Enrichment, and ARP ESSER Afterschool grant programs in accordance with PDE policy and Section 2 CFR 200.344 of the Uniform Guidance. QUESTIONED COST: None CAUSE: As a result of staff turnover, the School District inadvertently did not complete and file the Final Expenditure Reports with PDE in a timely manner. RECOMMENDATION: I recommend that the District develop fiscal procedures to ensure that ‘Final Expenditure Reports’ for future fiscal years are completed and filed in a timely manner based on supporting financial information obtained from the District’s business office, in order to 1) comply with PDE reporting requirements for the District’s applicable federal programs, and 2) to avoid any future sanctions or withholding of grant monies from PDE as a result of not filing these reports in a timely manner. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
2024 -007 - Noncompliance with Period of Performance Requirements State Entity: University of Louisiana at Lafayette (UL Lafayette) Award Years: 2021, 2022 Award Numbers: 80NSSC21M0165, DE-FE0031919 Compliance Requirement: Period of Performance Repeat Finding: No See Schedule of Findings and Questioned Costs for chart/table. Condition: UL Lafayette did not ensure that all expenses charged to federal Research and Development (R&D) awards complied with the period of performance requirements. From a population of 166 R&D grants with expenses totaling $6,720,454 and periods of performance starting or ending during the fiscal year ending June 30, 2024, a non-statistical sample of 17 grants was tested for compliance with period of performance requirements. For two (11.8%) of the 17 grants tested, expenses totaling $63,790 were identified as noncompliant with the period of performance requirements. One grant had expenses totaling $28,833 that were incurred after the period of performance. For the other grant, UL Lafayette failed to liquidate obligations totaling $34,957 incurred during the period of performance within 120 days after the end the period of performance as required by federal regulations. Criteria: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance [2 CFR sections 200.308, 200.309, and 200.403(h)]. Additionally, 2 CFR 200.344 states that 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. Cause: UL Lafayette did not have sufficient internal controls to ensure that only expenses incurred during the period of performance were charged to R&D grants and that obligations were liquidated timely. Effect: Noncompliance with the period of performance requirements resulted in $63,790 in questioned costs and increases the risk that expenses could be disallowed and not reimbursed by the awarding agency. Recommendation: Management should strengthen their procedures and internal controls that are in place to ensure that all expenses incurred on federal R&D grants comply with the period of performance requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-62).
2024 -007 - Noncompliance with Period of Performance Requirements State Entity: University of Louisiana at Lafayette (UL Lafayette) Award Years: 2021, 2022 Award Numbers: 80NSSC21M0165, DE-FE0031919 Compliance Requirement: Period of Performance Repeat Finding: No See Schedule of Findings and Questioned Costs for chart/table. Condition: UL Lafayette did not ensure that all expenses charged to federal Research and Development (R&D) awards complied with the period of performance requirements. From a population of 166 R&D grants with expenses totaling $6,720,454 and periods of performance starting or ending during the fiscal year ending June 30, 2024, a non-statistical sample of 17 grants was tested for compliance with period of performance requirements. For two (11.8%) of the 17 grants tested, expenses totaling $63,790 were identified as noncompliant with the period of performance requirements. One grant had expenses totaling $28,833 that were incurred after the period of performance. For the other grant, UL Lafayette failed to liquidate obligations totaling $34,957 incurred during the period of performance within 120 days after the end the period of performance as required by federal regulations. Criteria: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance [2 CFR sections 200.308, 200.309, and 200.403(h)]. Additionally, 2 CFR 200.344 states that 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. Cause: UL Lafayette did not have sufficient internal controls to ensure that only expenses incurred during the period of performance were charged to R&D grants and that obligations were liquidated timely. Effect: Noncompliance with the period of performance requirements resulted in $63,790 in questioned costs and increases the risk that expenses could be disallowed and not reimbursed by the awarding agency. Recommendation: Management should strengthen their procedures and internal controls that are in place to ensure that all expenses incurred on federal R&D grants comply with the period of performance requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-62).
Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development (HUD) Entity: City of Portsmouth (the City) Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listing: 14.218 Federal Award Identification Number and Year: None, 2023 Pass-Through Entity: N/A Award Number and Period: B-23-MC-51-0018 (7/1/23-9/1/30) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge to the Federal award 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. Further, the Uniform Guidance in 2 CFR 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 obligation incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control: Per 2 CFR Section 200.303(a), a 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 comply 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). Condition: The City of Portsmouth charged costs to the program that were incurred outside of the grant. award's period of performance. Context: One of Five expenditure transactions selected for testing, totaling $ 1,000, were incurred before the award start date of July 1, 2023. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program's review process did not detect the errors nor take timely corrective action. Effect: The City of Portsmouth was not compliant with the grant's period of performance which could result in the grantor's disallowance of the costs. Questioned costs: $1,000. Recommendation: We recommend that the City of Portsmouth review its procedures to ensure that expenditures charged to the program are incurred within the grant's period of performance. Views of Responsible Officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development (HUD) Entity: City of Portsmouth (the City) Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listing: 14.218 Federal Award Identification Number and Year: None, 2023 Pass-Through Entity: N/A Award Number and Period: B-23-MC-51-0018 (7/1/23-9/1/30) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge to the Federal award 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. Further, the Uniform Guidance in 2 CFR 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 obligation incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control: Per 2 CFR Section 200.303(a), a 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 comply 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). Condition: The City of Portsmouth charged costs to the program that were incurred outside of the grant. award's period of performance. Context: One of Five expenditure transactions selected for testing, totaling $ 1,000, were incurred before the award start date of July 1, 2023. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program's review process did not detect the errors nor take timely corrective action. Effect: The City of Portsmouth was not compliant with the grant's period of performance which could result in the grantor's disallowance of the costs. Questioned costs: $1,000. Recommendation: We recommend that the City of Portsmouth review its procedures to ensure that expenditures charged to the program are incurred within the grant's period of performance. Views of Responsible Officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development (HUD) Entity: City of Portsmouth (the City) Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listing: 14.218 Federal Award Identification Number and Year: None, 2023 Pass-Through Entity: N/A Award Number and Period: B-23-MC-51-0018 (7/1/23-9/1/30) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge to the Federal award 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. Further, the Uniform Guidance in 2 CFR 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 obligation incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control: Per 2 CFR Section 200.303(a), a 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 comply 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). Condition: The City of Portsmouth charged costs to the program that were incurred outside of the grant. award's period of performance. Context: One of Five expenditure transactions selected for testing, totaling $ 1,000, were incurred before the award start date of July 1, 2023. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program's review process did not detect the errors nor take timely corrective action. Effect: The City of Portsmouth was not compliant with the grant's period of performance which could result in the grantor's disallowance of the costs. Questioned costs: $1,000. Recommendation: We recommend that the City of Portsmouth review its procedures to ensure that expenditures charged to the program are incurred within the grant's period of performance. Views of Responsible Officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development (HUD) Entity: City of Portsmouth (the City) Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listing: 14.218 Federal Award Identification Number and Year: None, 2023 Pass-Through Entity: N/A Award Number and Period: B-23-MC-51-0018 (7/1/23-9/1/30) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge to the Federal award 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. Further, the Uniform Guidance in 2 CFR 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 obligation incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control: Per 2 CFR Section 200.303(a), a 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 comply 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). Condition: The City of Portsmouth charged costs to the program that were incurred outside of the grant. award's period of performance. Context: One of Five expenditure transactions selected for testing, totaling $ 1,000, were incurred before the award start date of July 1, 2023. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program's review process did not detect the errors nor take timely corrective action. Effect: The City of Portsmouth was not compliant with the grant's period of performance which could result in the grantor's disallowance of the costs. Questioned costs: $1,000. Recommendation: We recommend that the City of Portsmouth review its procedures to ensure that expenditures charged to the program are incurred within the grant's period of performance. Views of Responsible Officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development (HUD) Entity: City of Portsmouth (the City) Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listing: 14.218 Federal Award Identification Number and Year: None, 2023 Pass-Through Entity: N/A Award Number and Period: B-23-MC-51-0018 (7/1/23-9/1/30) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge to the Federal award 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. Further, the Uniform Guidance in 2 CFR 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 obligation incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control: Per 2 CFR Section 200.303(a), a 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 comply 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). Condition: The City of Portsmouth charged costs to the program that were incurred outside of the grant. award's period of performance. Context: One of Five expenditure transactions selected for testing, totaling $ 1,000, were incurred before the award start date of July 1, 2023. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program's review process did not detect the errors nor take timely corrective action. Effect: The City of Portsmouth was not compliant with the grant's period of performance which could result in the grantor's disallowance of the costs. Questioned costs: $1,000. Recommendation: We recommend that the City of Portsmouth review its procedures to ensure that expenditures charged to the program are incurred within the grant's period of performance. Views of Responsible Officials: Management agrees with the finding.
Finding 2024-001 Reporting – Internal Control and Compliance over Reporting (Significant Deficiency) Information on the Federal Program: Assistance Listing Number: 14.218 Federal Program Name: CDBG‐Entitlement Grants Cluster Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: N/A Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21 B-21-MC-06-0053 – FY21-22 B-22-MC-06-0053 – FY22-23 B-23-MC-06-0053 – FY23-24 Criteria: Code of Federal Regulations, Title 2 – Federal Financial Assistance, Subtitle A – Office of Management and Budget Guidance for Federal Financial Assistance, Chapter II – Office of Management and Budget Guidance, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements: Performance and Financial Monitoring and Reporting Section § 200.328 Financial reporting. (a) The Federal agency must require only OMB-approved government-wide data elements on recipient financial reports. At the time of publication, this consists of the Federal Financial Report (SF-425); however, this also applies to any future OMB-approved government-wide data elements available from the OMB-designated standards lead. (b) The Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports. (c) The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient 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. (d) The final financial report submitted by the recipient must be due no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must submit a final financial report to a pass-through entity no later than 90 calendar days after the conclusion of the period of performance. See also § 200.344. The Federal agency or pass-through entity may extend the due date for any financial report with justification from the recipient or subrecipient. Section § 200.303 Internal Controls The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context: For the Community Development Block Grants/Entitlement Grants Cluster, the City did not submit the reports within the required deadline: Report Type Award Number Period Date Due Date Submitted SF-425 Financial Program-wide reporting 7/1/2023 - 9/30/2023 10/30/2023 1/16/2024 SF-425 Financial Program-wide reporting 1/1/2024 - 3/31/2024 3/30/2024 7/24/2024 Four (4) quarterly financial reports were tested, and two (2) reports were not submitted by the required deadline. Cause: During the audit period, the City did not possess the operational processes/procedures necessary to guarantee timely submission of the SF-425 report. Effect: Failure to submit the SF-425 reports timely results in noncompliance with the reporting requirements in the grant agreement. Questioned Costs: None noted. Identification as a Repeat Finding, If Applicable: No. Recommendation: We recommend that the City strengthen their report submission process and procedures to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval. Management’s View and Corrective Action Plan: The City agrees with this finding. The City has already taken steps to improve its processes/procedures to insure timely submission of all required SF-425 reports.
Finding 2024-001 Reporting – Internal Control and Compliance over Reporting (Significant Deficiency) Information on the Federal Program: Assistance Listing Number: 14.218 Federal Program Name: CDBG‐Entitlement Grants Cluster Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: N/A Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21 B-21-MC-06-0053 – FY21-22 B-22-MC-06-0053 – FY22-23 B-23-MC-06-0053 – FY23-24 Criteria: Code of Federal Regulations, Title 2 – Federal Financial Assistance, Subtitle A – Office of Management and Budget Guidance for Federal Financial Assistance, Chapter II – Office of Management and Budget Guidance, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements: Performance and Financial Monitoring and Reporting Section § 200.328 Financial reporting. (a) The Federal agency must require only OMB-approved government-wide data elements on recipient financial reports. At the time of publication, this consists of the Federal Financial Report (SF-425); however, this also applies to any future OMB-approved government-wide data elements available from the OMB-designated standards lead. (b) The Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports. (c) The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient 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. (d) The final financial report submitted by the recipient must be due no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must submit a final financial report to a pass-through entity no later than 90 calendar days after the conclusion of the period of performance. See also § 200.344. The Federal agency or pass-through entity may extend the due date for any financial report with justification from the recipient or subrecipient. Section § 200.303 Internal Controls The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context: For the Community Development Block Grants/Entitlement Grants Cluster, the City did not submit the reports within the required deadline: Report Type Award Number Period Date Due Date Submitted SF-425 Financial Program-wide reporting 7/1/2023 - 9/30/2023 10/30/2023 1/16/2024 SF-425 Financial Program-wide reporting 1/1/2024 - 3/31/2024 3/30/2024 7/24/2024 Four (4) quarterly financial reports were tested, and two (2) reports were not submitted by the required deadline. Cause: During the audit period, the City did not possess the operational processes/procedures necessary to guarantee timely submission of the SF-425 report. Effect: Failure to submit the SF-425 reports timely results in noncompliance with the reporting requirements in the grant agreement. Questioned Costs: None noted. Identification as a Repeat Finding, If Applicable: No. Recommendation: We recommend that the City strengthen their report submission process and procedures to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval. Management’s View and Corrective Action Plan: The City agrees with this finding. The City has already taken steps to improve its processes/procedures to insure timely submission of all required SF-425 reports.
Finding 2024-001 Reporting – Internal Control and Compliance over Reporting (Significant Deficiency) Information on the Federal Program: Assistance Listing Number: 14.218 Federal Program Name: CDBG‐Entitlement Grants Cluster Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: N/A Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21 B-21-MC-06-0053 – FY21-22 B-22-MC-06-0053 – FY22-23 B-23-MC-06-0053 – FY23-24 Criteria: Code of Federal Regulations, Title 2 – Federal Financial Assistance, Subtitle A – Office of Management and Budget Guidance for Federal Financial Assistance, Chapter II – Office of Management and Budget Guidance, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements: Performance and Financial Monitoring and Reporting Section § 200.328 Financial reporting. (a) The Federal agency must require only OMB-approved government-wide data elements on recipient financial reports. At the time of publication, this consists of the Federal Financial Report (SF-425); however, this also applies to any future OMB-approved government-wide data elements available from the OMB-designated standards lead. (b) The Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports. (c) The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient 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. (d) The final financial report submitted by the recipient must be due no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must submit a final financial report to a pass-through entity no later than 90 calendar days after the conclusion of the period of performance. See also § 200.344. The Federal agency or pass-through entity may extend the due date for any financial report with justification from the recipient or subrecipient. Section § 200.303 Internal Controls The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context: For the Community Development Block Grants/Entitlement Grants Cluster, the City did not submit the reports within the required deadline: Report Type Award Number Period Date Due Date Submitted SF-425 Financial Program-wide reporting 7/1/2023 - 9/30/2023 10/30/2023 1/16/2024 SF-425 Financial Program-wide reporting 1/1/2024 - 3/31/2024 3/30/2024 7/24/2024 Four (4) quarterly financial reports were tested, and two (2) reports were not submitted by the required deadline. Cause: During the audit period, the City did not possess the operational processes/procedures necessary to guarantee timely submission of the SF-425 report. Effect: Failure to submit the SF-425 reports timely results in noncompliance with the reporting requirements in the grant agreement. Questioned Costs: None noted. Identification as a Repeat Finding, If Applicable: No. Recommendation: We recommend that the City strengthen their report submission process and procedures to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval. Management’s View and Corrective Action Plan: The City agrees with this finding. The City has already taken steps to improve its processes/procedures to insure timely submission of all required SF-425 reports.
Finding 2024-001 Reporting – Internal Control and Compliance over Reporting (Significant Deficiency) Information on the Federal Program: Assistance Listing Number: 14.218 Federal Program Name: CDBG‐Entitlement Grants Cluster Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: N/A Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21 B-21-MC-06-0053 – FY21-22 B-22-MC-06-0053 – FY22-23 B-23-MC-06-0053 – FY23-24 Criteria: Code of Federal Regulations, Title 2 – Federal Financial Assistance, Subtitle A – Office of Management and Budget Guidance for Federal Financial Assistance, Chapter II – Office of Management and Budget Guidance, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements: Performance and Financial Monitoring and Reporting Section § 200.328 Financial reporting. (a) The Federal agency must require only OMB-approved government-wide data elements on recipient financial reports. At the time of publication, this consists of the Federal Financial Report (SF-425); however, this also applies to any future OMB-approved government-wide data elements available from the OMB-designated standards lead. (b) The Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports. (c) The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient 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. (d) The final financial report submitted by the recipient must be due no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must submit a final financial report to a pass-through entity no later than 90 calendar days after the conclusion of the period of performance. See also § 200.344. The Federal agency or pass-through entity may extend the due date for any financial report with justification from the recipient or subrecipient. Section § 200.303 Internal Controls The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context: For the Community Development Block Grants/Entitlement Grants Cluster, the City did not submit the reports within the required deadline: Report Type Award Number Period Date Due Date Submitted SF-425 Financial Program-wide reporting 7/1/2023 - 9/30/2023 10/30/2023 1/16/2024 SF-425 Financial Program-wide reporting 1/1/2024 - 3/31/2024 3/30/2024 7/24/2024 Four (4) quarterly financial reports were tested, and two (2) reports were not submitted by the required deadline. Cause: During the audit period, the City did not possess the operational processes/procedures necessary to guarantee timely submission of the SF-425 report. Effect: Failure to submit the SF-425 reports timely results in noncompliance with the reporting requirements in the grant agreement. Questioned Costs: None noted. Identification as a Repeat Finding, If Applicable: No. Recommendation: We recommend that the City strengthen their report submission process and procedures to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval. Management’s View and Corrective Action Plan: The City agrees with this finding. The City has already taken steps to improve its processes/procedures to insure timely submission of all required SF-425 reports.
Other Matter – Non-Major Federal Award Program 2024-002. Questioned Costs United States of Department of Education, Passed Through New York State, Department of Education: Special Education Cluster Special Education Grants to States: IDEA Part B ALN: 84.027 Pass-through Entity Number: 0032-23-0415 Criteria: Pursuant to Federal regulations 2 CFR §200.344(e), a subrecipient of a Federal award must promptly refund any unobligated funds that the Federal agency or pass-through entity paid that are not authorized to be retained. Condition: The District received total reimbursement for its 2022-2023 IDEA, Part B (Section 611) Federal grant award that exceeded the program’s final total expenditures, but did not notify the pass-through entity of the overpayment to refund the overpayment. Cause: Some of the amounts reported in the District’s final expenditure report (Form FS-10F) submitted to the pass-through entity, the New York State Education Department (NYSED), for its 2022-2023 IDEA, Part B (Section 611) grant award were for accrued expenditures based on open encumbrances that did not materialize. The District’s Business Office adjusted the records in their accounting system but neglected to contact the pass-through entity for instructions to submit a corrected final expenditure report and refund the overpaid reimbursement. Effect: The failure to notify the pass-through entity of unentitled Federal grant monies and promptly refund unentitled monies is noncompliant with Federal regulations and could affect amounts of future grant awards or their approval. Questioned Costs: $60,184. Context: On its revised Form FS-10F final expenditure report for the 2022-23 IDEA, Part B Section 611 grant award, which was submitted to the NYSED on March 6, 2024, the District reported amounts for three vendors totaling $62,199 that were recorded as accounts payable based on open encumbrances. Subsequently, in October 2024, the District determined that only $2,015 for one vendor was a valid expenditure and outstanding accounts payable, and adjusted its accounting records for the year ended June 30, 2024, while the external audit of its annual financial statements was under way. The District did not contact the NYSED about the invalid expenditures claimed on its Form FS-10F final expenditure report. Identification of a Repeat Finding: This is not a repeat finding from the immediately prior audit. Recommendation: The District should notify the NYSED of the overpayment and obtain instructions for how to refund the overpayment. The District should also implement procedures to ensure discrepancies between amounts reported in final expenditure reports and accounting records are reconciled and corrected final reports are submitted to the NYSED timely. Views of Responsible Officials of Auditee: The District agrees with the finding. The District’s Assistant Business Administrator will contact the NYSED and submit a corrected final expenditure report, and begin the overpayment refund process.
2024-017 The Housing Finance Commission did not have adequate internal controls over reporting requirements for the Homeowner Assistance Fund program. Assistance Listing Number and Title: 21.026 COVID-19 Homeowner Assistance Fund Federal Grantor Name: U.S. Department of the Treasury Federal Award/Contract Number: None Pass-through Entity Name: None Pass-through Award/Contract Number: None Applicable Compliance Component: Reporting Known Questioned Cost Amount: None Prior Year Audit Finding: Yes, Finding 2023-025 Background The American Rescue Plan Act of 2021 provided $9.96 billion to the Homeowner Assistance Fund (HAF) program. The U.S. Department of the Treasury provides funds directly to states, U.S. territories and Indian tribes to assist eligible homeowners experiencing financial hardship due to the COVID-19 pandemic. Program funds can be used to prevent mortgage delinquencies and defaults, foreclosures, loss of utilities or home energy services, and homeowner displacement. The law prioritizes funds for homeowners who have experienced hardships, leveraging local and national income indicators to maximize the program’s impact. The Housing Finance Commission administers the HAF program in Washington. In fiscal year 2024, the Commission spent about $70.8 million in HAF funds. The Commission implemented a pilot program before launching the main HAF program. The Commission contracted with a contractor to help implement the main HAF program and maintain participant data. The Commission is required to submit an annual performance report that provides an overview of its intended and actual uses of funding to-date for the pilot and main HAF programs. The federal grantor identified two key lines items on the report that contained critical information: 1. Socially Disadvantaged Individuals (SDIs) – Quantifiable Objective Criteria: Participants are providing not less than 60% of funds to homeowners with income less than 100% area median income (AMI) or 100% of U.S. median income. 2. AMI – Quantifiable Objective Criteria: Participants target homeowners that are classified as SDI and 100% AMI or less. The HAF Plan, approved by the federal grantor, outlines the budget allocations, goals and types of assistance for the Washington HAF program. The HAF reporting portal automatically populates each section of the annual report template with information from this plan. The Commission is required to submit a narrative on the status of each section. Commission staff use participant data provided by the contractor to complete the report template. Once completed, the preparer submits the report in the HAF reporting portal without management review. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. In prior audits, we reported the Commission did not have adequate internal controls over and did not comply with reporting requirements. The prior finding number was 2023-025. Description of Condition The Commission did not have adequate internal controls over reporting requirements for the HAF program. The contractor only provided summary-level data to the Commission at the time of reporting. As a result, Commission staff did not have detailed supporting documentation to review to verify that the total amounts in the contractor’s reports were complete and accurate. Additionally, the Commission did not have documented evidence to support that management reviewed the annual report before submission. We consider these internal control deficiencies to be a material weakness. Cause of Condition The Commission did not require the contractor to submit detailed support for the total numbers provided for reporting to ensure all categories were included. Additionally, the Commission did not ensure adequate management review of the report before submission. Effect of Condition Without establishing adequate internal controls, which should include reviewing the reports and the detailed supporting documentation to ensure the correct data is reported, management cannot ensure that the reports are complete and accurate. Recommendations We recommend the Commission: • Establish effective internal controls to ensure the reports are accurate and complete • Ensure that management performs and documents an adequate review of the supporting documentation before submitting reports to the grantor Commission’s Response The Commission concurs with this finding. The Commission has implemented a system of controls and management review to ensure that data reported to the federal grantor is complete and accurate. The auditor’s recommendations came after the FY 23 Annual Report was filed and will be reflected in the upcoming FY24 Annual Report. The new process has been used in the quarterly reporting. Auditor’s Remarks We thank the Commission for its cooperation and assistance throughout the audit. We will review the status of the Commission's corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 CFR Part 200, Uniform Guidance, section 328, Financial reporting, states: (a) The Federal agency must require only OMB-approved government-wide data elements on recipient financial reports. At the time of publication, this consists of the Federal Financial Report (SF-425); however, this also applies to any future OMB-approved government-wide data elements available from the OMB-designated standards lead. (b) The Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports. (c) The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient 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. (d) The final financial report submitted by the recipient must be due no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must submit a final financial report to a pass-through entity no later than 90 calendar days after the conclusion of the period of performance. See also § 200.344. The Federal agency or pass-through entity may extend the due date for any financial report with justification from the recipient or subrecipient. Title 2 CFR Part 200, Uniform Guidance, section 516, Audit findings, establishes reporting requirements for audit findings. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. The U.S. Department of the Treasury’s Homeowner Assistance Fund: Guidance on Participant Compliance and Reporting Responsibilities, states, in part: Programmatic Information Requirements HAF participants are required to submit an Annual Performance Report on an annual basis and demonstrate the impact of the HAF-financed programs. Reports should include data related to program outputs and outcomes against the stated objectives of the HAF participant’s HAF Grant Plan. Performance Goals HAF participants initially submitted performance goals on the use of HAF awarded funds in their approved Grantee Plan. Each one of the performance goals should have identified how the HAF participant will address homeowner needs and should have been disaggregated by key characteristics such as mortgage type, racial and ethnic demographics, and/or geographic areas, as appropriate. HAF participants will be required to provide a status update and quantitative measures, if applicable, on each of their initial performance goals set forth in their Grantee Plan. Please note, HAF participants will not have the ability to alter their original performance goals noted in their Grantee Plan nor add additional performance goals in the Annual Report. Methods for Targeting and HAF Funding HAF participants were asked in their original Grantee Plan to describe how the HAF participant will effectively target HAF award funds to (1) homeowners with incomes equal to or less than 100% of the area median income or equal to or less than 100% of the median income for the United States, whichever is greater; and (2) socially disadvantaged individuals. The description included the HAF participant’s targeting strategies. HAF participants will be required to provide an update on their targeting methods and if they have appropriately executed targeting methods according to their original Grantee Plan.
Finding No. 2024-035 Federal Awarding Agency: USDOD Impact: Significant Deficiency, Noncompliance AL Number and Title: 12.401 NGMOMP Federal Award Number: W91ZRU-23-2-1001, W91ZRU-23-2-1004, W91ZRU-23-2-1005, W91ZRU-23-2-1010, W91ZRU-23-2-1021E, W91ZRU-23-2-1021K, W91ZRU-23-2-1040 Applicable Compliance Requirement: Period of Performance Condition: Six of seven award extensions for the NGMOMP program were untimely. Additionally, one award was not closed timely. Context: National Guard Bureau Grants and Cooperative Agreement Policy Letter 21-07, effective date July 19, 2021, revised the program period of performance requirements for extension requests to be submitted no later than 10 days prior to the end of the 120-day award closeout period. Award extension requests were required to be submitted no later than January 21, 2024. Three of the six extension requests were submitted on January 30, 2024 (nine days late); two were submitted on January 25, 2024 (six days late); and one was submitted on January 22, 2024 (one day late). The policy letter also revised the timeframe for award closeout requiring the grantee to conduct closeout within 120 calendar days from the end of the period of performance. Two awards closed during FY 24, of which one did not have a final accounting submitted within the 120 days. Award closeout was submitted approximately 200 days after the end of the period of performance or approximately 80 days late. Cause: DMVA has written procedures for federal extension requests and award closure. However, competing priorities resulted in untimely submission of extension requests. The final reimbursement requests were submitted to USDOD on January 25, 2024, six days before the end of the closeout period. Federal payment was not received until March 19, 2024. Due, in part, to the untimely receipt of the payments, closeout documentation was not signed by all necessary parties until April 13, 2024. Criteria: Per Title 2 CFR 200.308(e)(2) all requests for one-time extension should be submitted at least 10 calendar days before the conclusion of the period of performance. Title 2 CFR 200.344 prescribes the pass-through entity must close out the federal award when it determines that all administrative actions and required work of the federal award have been completed. A recipient must submit all reports and liquidate all financial obligations no later than 120 days after the conclusion of the period of performance. Title 2 CFR 200.303(a) requires the State to establish and maintain effective internal controls over federal awards that provide reasonable assurance that the State is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Effect: Untimely award extension requests and award closeouts may result in unallowable program expenditures. Questioned Costs: None Recommendation: DMVA’s DAS director should follow procedures to ensure cooperative award extensions and award closeout documents are submitted timely, including requesting final payments timely, given the extended timeframe for federal reimbursement. Views of Responsible Officials: Management agrees with this finding.
Condition: During the test of 100 % of projects, sixteen (16) projects, for the Coronavirus State and Local Fiscal Recovery Funds, the following noncompliance with the Reporting compliance requirement was noted: • The third quarter report was not submitted. • The fourth quarter report was not timely submitted. • Four (4) projects were coded as revenue loss and should have been coded to an administrative expense code. • Four (4) projects were coded as revenue loss and should have been coded as a subrecipient. • Two (2) projects were coded as a subrecipient and were not a subrecipient relationship. After the review of the quarterly reports, the following exceptions were noted: • The second quarter report was understated by $257,160. • Health Department reported cumulative total of $1,090,483 in expenditures; however, disbursements totaled $1,089,725. • Emergency Management reported cumulative total of $276,279 in expenditures; however, disbursements totaled $333,169. • Rogers County Sheriff reported cumulative total of $300,000 in expenditures; however, disbursements totaled $233,344. • The consultant hired by the county to administer the grant reported cumulative total of $251,427 in expenditures; however, disbursements totaled was $287,346. Jail Remodel had expenditures of $231,765; however, it was no expenditures were listed on the report. 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.
2 CFR 200.328 states, in part, (c) the recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient 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. (d) The final financial report submitted by the recipient must be due no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must submit a final financial report to a pass-through entity no later than 90 calendar days after the conclusion of the period of performance. See also § 200.344. The Federal agency or pass-through entity may extend the due date for any financial report with justification from the recipient or subrecipient. Further, 2 CFR 200.502(a) states that the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. We noted that the District filed its FY23 final expenditure report by the required deadline. However, the District claimed $476,752 more in expenditures on the final expenditure report than they had identified in eligible expenditures for the program. The District reclassified $476,752 in ESSER expenditures from the general fund into the ESSER fund after the reporting deadline. We noted that this determination was made after the obligation period had ended and without an extension request being made to the pass-through agency, Ohio Department of Education and Workforce (ODEW) to extend the due date. Further, the ESSER expenditures adjusted from the general fund did not align with the object codes budgeted with ODEW through the Comprehensive Continuous Improvement Plan and reported on the final expenditure report. Additionally, system reports originally filed with ODEW along with the final expenditure report did not accurately reflect the expenditures ultimately claimed for the program. We recommend that the District adopt proper procedures to ensure that reported expenditures on the final expenditure report are accurate and obligated by the appropriate deadline. Requests to extend the due date of the reporting requirement should be made when necessary. Further, expenditures should only be made for objects budgeted and approved by ODEW. In instances where reclassifications are made to program expenditures, the District should ensure that revisions to previously submitted reports are made, when necessary.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 93.242 and 93.853, U.S. Department of Health and Human Services - 47.041 and 47.049, National Science Foundation - 84.326, U.S. Department of Education Federal Award Identification Number and Year - Research and Development Cluster: - 93.242 - 5 F31 MH125541-03 - 93.853 - 5 U01 NS120910 02; 1 R61 NS128232-01 - 47.041 - CMMI 2151465; CBET-2125056 EAGER - 47.049 - CHE 1900097; CHE-1955161 - 84.326 - H326T230006-1- FY24-28 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.344, a recipient 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 and must have controls in place as part of that liquidation process in order to ensure that all costs charged to the grant were incurred during the period of performance. Condition - The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related to timeliness of grant closeout procedures. Context - In all samples tested, grant closeout procedures were completed; however, they were outside of an effective time window in order to meet the CFR requirements. The late reviews occurred between 134 days and 262 days after the period of performance ended. Two of the grant closeout checklists were not reviewed by an independent person once they were prepared. Cause and Effect - The University does have a formal grant closeout process in place, which includes a level of review of the grant checklist complete; however, the procedures were not followed or were misunderstood by certain staff, leading to procedures being completed late and a lack of review. Recommendation - The University should implement additional training over the procedures in place and consider whether any additional controls should be designed to mitigate the risk of procedures and reviews not being done in a timely manner. Views of Responsible Officials and Corrective Action Plan - SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 93.242 and 93.853, U.S. Department of Health and Human Services - 47.041 and 47.049, National Science Foundation - 84.326, U.S. Department of Education Federal Award Identification Number and Year - Research and Development Cluster: - 93.242 - 5 F31 MH125541-03 - 93.853 - 5 U01 NS120910 02; 1 R61 NS128232-01 - 47.041 - CMMI 2151465; CBET-2125056 EAGER - 47.049 - CHE 1900097; CHE-1955161 - 84.326 - H326T230006-1- FY24-28 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.344, a recipient 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 and must have controls in place as part of that liquidation process in order to ensure that all costs charged to the grant were incurred during the period of performance. Condition - The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related to timeliness of grant closeout procedures. Context - In all samples tested, grant closeout procedures were completed; however, they were outside of an effective time window in order to meet the CFR requirements. The late reviews occurred between 134 days and 262 days after the period of performance ended. Two of the grant closeout checklists were not reviewed by an independent person once they were prepared. Cause and Effect - The University does have a formal grant closeout process in place, which includes a level of review of the grant checklist complete; however, the procedures were not followed or were misunderstood by certain staff, leading to procedures being completed late and a lack of review. Recommendation - The University should implement additional training over the procedures in place and consider whether any additional controls should be designed to mitigate the risk of procedures and reviews not being done in a timely manner. Views of Responsible Officials and Corrective Action Plan - SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 93.242 and 93.853, U.S. Department of Health and Human Services - 47.041 and 47.049, National Science Foundation - 84.326, U.S. Department of Education Federal Award Identification Number and Year - Research and Development Cluster: - 93.242 - 5 F31 MH125541-03 - 93.853 - 5 U01 NS120910 02; 1 R61 NS128232-01 - 47.041 - CMMI 2151465; CBET-2125056 EAGER - 47.049 - CHE 1900097; CHE-1955161 - 84.326 - H326T230006-1- FY24-28 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.344, a recipient 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 and must have controls in place as part of that liquidation process in order to ensure that all costs charged to the grant were incurred during the period of performance. Condition - The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related to timeliness of grant closeout procedures. Context - In all samples tested, grant closeout procedures were completed; however, they were outside of an effective time window in order to meet the CFR requirements. The late reviews occurred between 134 days and 262 days after the period of performance ended. Two of the grant closeout checklists were not reviewed by an independent person once they were prepared. Cause and Effect - The University does have a formal grant closeout process in place, which includes a level of review of the grant checklist complete; however, the procedures were not followed or were misunderstood by certain staff, leading to procedures being completed late and a lack of review. Recommendation - The University should implement additional training over the procedures in place and consider whether any additional controls should be designed to mitigate the risk of procedures and reviews not being done in a timely manner. Views of Responsible Officials and Corrective Action Plan - SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 93.242 and 93.853, U.S. Department of Health and Human Services - 47.041 and 47.049, National Science Foundation - 84.326, U.S. Department of Education Federal Award Identification Number and Year - Research and Development Cluster: - 93.242 - 5 F31 MH125541-03 - 93.853 - 5 U01 NS120910 02; 1 R61 NS128232-01 - 47.041 - CMMI 2151465; CBET-2125056 EAGER - 47.049 - CHE 1900097; CHE-1955161 - 84.326 - H326T230006-1- FY24-28 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.344, a recipient 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 and must have controls in place as part of that liquidation process in order to ensure that all costs charged to the grant were incurred during the period of performance. Condition - The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related to timeliness of grant closeout procedures. Context - In all samples tested, grant closeout procedures were completed; however, they were outside of an effective time window in order to meet the CFR requirements. The late reviews occurred between 134 days and 262 days after the period of performance ended. Two of the grant closeout checklists were not reviewed by an independent person once they were prepared. Cause and Effect - The University does have a formal grant closeout process in place, which includes a level of review of the grant checklist complete; however, the procedures were not followed or were misunderstood by certain staff, leading to procedures being completed late and a lack of review. Recommendation - The University should implement additional training over the procedures in place and consider whether any additional controls should be designed to mitigate the risk of procedures and reviews not being done in a timely manner. Views of Responsible Officials and Corrective Action Plan - SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 93.242 and 93.853, U.S. Department of Health and Human Services - 47.041 and 47.049, National Science Foundation - 84.326, U.S. Department of Education Federal Award Identification Number and Year - Research and Development Cluster: - 93.242 - 5 F31 MH125541-03 - 93.853 - 5 U01 NS120910 02; 1 R61 NS128232-01 - 47.041 - CMMI 2151465; CBET-2125056 EAGER - 47.049 - CHE 1900097; CHE-1955161 - 84.326 - H326T230006-1- FY24-28 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.344, a recipient 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 and must have controls in place as part of that liquidation process in order to ensure that all costs charged to the grant were incurred during the period of performance. Condition - The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related to timeliness of grant closeout procedures. Context - In all samples tested, grant closeout procedures were completed; however, they were outside of an effective time window in order to meet the CFR requirements. The late reviews occurred between 134 days and 262 days after the period of performance ended. Two of the grant closeout checklists were not reviewed by an independent person once they were prepared. Cause and Effect - The University does have a formal grant closeout process in place, which includes a level of review of the grant checklist complete; however, the procedures were not followed or were misunderstood by certain staff, leading to procedures being completed late and a lack of review. Recommendation - The University should implement additional training over the procedures in place and consider whether any additional controls should be designed to mitigate the risk of procedures and reviews not being done in a timely manner. Views of Responsible Officials and Corrective Action Plan - SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 232MI013W5003 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2023-004 Criteria - Per 2 CFR 200.344(c), unless the federal awarding agency or pass through entity authorizes an extension, a nonfederal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end of the period of performance, as specified in the terms and conditions of the federal award. However, as outlined within the grant award from the Michigan Department of Health and Human Services and more restrictive than 2 CFR 200.344(c), the City must liquidate within 60 days after the State's fiscal year end any unpaid year end commitments and obligations. Any obligation remaining unliquidated after 60 days from the end of the period shall revert to the State for disposition in accordance with applicable state and/or federal requirements, except as specifically authorized in writing by the department. Condition - The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days from the end of the grant period and certain costs were liquidated after 60 days. Questioned Costs - None Identification of How Questioned Costs Were Computed - Refer to context below. Context - There were two invoices totaling $251,332 that were not paid at the end of the grant period. A review of both invoices revealed that they were liquidated after the required 60 days for the performance period ended September 30, 2023. Based on email communication received by the City from the Michigan Department of Health and Human Services, the department granted the City retroactive approval to allow for the expenses despite being liquidated after the 60 day period. As a result, no questioned costs are reported. Cause and Effect - The controls in place were not effective to ensure grant expenditures were liquidated within 60 days following the end of the grant period. Failure to comply with the terms and conditions of the grant agreement, including the liquidation provisions, may result in disallowed costs and the need to repay the funder for such costs. Recommendation - We recommend the City ensure controls are in place to comply with liquidation requirements outlined in the award agreements and/or the Uniform Guidance issued by OMB (whichever is more restrictive). Views of Responsible Officials and Planned Corrective Actions - The Office of the Chief Financial Officer (OCFO) is collaborating with the Health Department to implement enhanced processes over the final review of invoices to address timing related to the liquidation requirement.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(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 as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.