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.
Condition: Expenditures for federal programs were not adequately reported on the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Compliance Reports. Federal expenditures were understated by $1,227,550. The actual expenditures to vendors were $1,272,002, the County reported $44,452. Cause of Condition: Policies and procedures have not been designed and implemented to ensure compliance with reporting compliance requirements. Effect of Condition: This condition could result in noncompliance to grant requirements and could result in unrecorded transactions, undetected errors, and misappropriation of assets and funds.Recommendation: OSAI recommends the County gain an understanding of the grant requirements for this program and implement internal controls to ensure compliance with these grant requirements. Management Response: Chairman of the Board of County Commissioners: I plan to communicate with the Budget Board regarding this finding and have already introduced to the Budget Board, a form guideline called “Payne County Grant Administration Plan” to aid in proper documentation, reporting and proper spending of all grant awards. I plan to discuss all findings with the Budget Board throughout the year during our Budget Board meetings to get updates on how the findings are actively being addressed by each department and get input on how to best combat future findings. I request that responses by the various departments be forwarded to me to ensure action is taken and for discussion during the meetings. Criteria: 2 CFR § 200.303 Internal Controls (a) reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of 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 outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, you organization needs to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Further, 2 CFR § 200.329 Monitoring and Reporting Program Performance (c)(1) reads as follows: The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance reports as required by the terms and conditions of the Federal award. See also § 200.344. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report.
2024-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the prior fiscal years were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The District is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2023-003. Recommendation: The District should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
Finding 2024-014 – Noncompliance with Reporting Requirements Over Federal Grant – Coronavirus State and Local Fiscal Recovery Fund (Repeat Finding – 2022-0014, 2023-0014) PASS THROUGH GRANTOR: Direct Grant FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Reporting QUESTIONED COSTS: $0 Condition: In the review of forty-seven (47) expenditures for federal programs, eleven (11) instances were noted where the expenditures were not correctly reported on the Coronavirus State and Local Fiscal Recovery Funds compliance reports. The expenditures were not reported in the correct quarter. 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 grant requirements. Recommendation: OSAI recommends the County design and implement a system of internal controls to ensure the accuracy and completeness of information submitted. Management Response: Chairman of the Board of County Commissioners: The Board of County Commissioners have hired a grant administrator to assist with the reporting process. We will ensure that the reports are accurate and reported in the proper period. Criteria: GAO Standards – Section 2 – Establishing an Effective Internal Control System – OV2.23 states in part: Objectives of an Entity – Compliance Objectives Management conducts activities in accordance with applicable laws and regulations. As part of specifying compliance objectives, the entity determines which laws and regulations apply to the entity. Management is expected to set objectives that incorporate these requirements. 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). Additionally, Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (10. Reporting.) reads as follows: 10. Reporting. All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, you organization needs to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Further, 2 CFR § 200.329 Monitoring and Reporting Program Performance (c)(1) reads as follows: The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance reports as required by the terms and conditions of the Federal award. See also § 200.344. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report.
Finding 2024-013 – Noncompliance with Reporting Requirements Over Federal Grant Coronavirus State and Local Fiscal Recovery Funds (Repeat Finding – 2022-013, 2023-013) PASS-THROUGH GRANTOR: Direct Grant FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Reporting QUESTIONED COSTS: $-0- Condition: The County has not established internal controls to ensure the correct expenditure category is used for reporting payments to the grant administrative contractor. The quarterly reports improperly classified payments totaling $29,578 to a contractor as a ‘Revenue Replacement’ expense instead of using the ‘Administrative’ expense category. Also, the quarterly reports improperly classified payments totaling $513,944 for the Resurrection House as a ‘Revenue Replacement’ expense instead of using the ‘Negative Economic Impact’ expense category as stated in the agreement with the Board of County Commissioners. This entity was also not reflected as a Beneficiary in the quarterly reports. Further, subrecipient agreements for the following pass-through entities were signed and approved by the Board of County Commissioners; however, the entities were not reported as subrecipients in the quarterly reports: • Town of Rush Springs • Grady County Rural Water #6 • Grady County Rural Water #7 • City of Chickasha • City of Minco Additionally, the expense category listed in the quarterly reports differs from the expense category listed in the subrecipient agreements for the following entities: • City of Chickasha • City of Minco Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with federal compliance requirements. Effect of Condition: This condition could result in noncompliance to grant requirements. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. Management Response: Chairman of the Board of County Commissioners: The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants. Criteria: Accountability and stewardship should be overall goals in management’s accounting of federal funds. Internal controls should be designed to monitor compliance with laws and regulations pertaining to grant contracts. Title 2 CFR § 200.303(a) Internal Controls reads (a) reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Controls Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (10. Reporting.) reads as follows: All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, your organization needs to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Further, 2 CFR § 200.329 Monitoring and Reporting Program Performance (c)(1) reads as follows: The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance reports as required by the terms and conditions of the Federal award. See also § 200.344. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report.
Criteria - According to HUD guidelines and Uniform Guidance (2 CFR 200.344) related to the Authority’s Public Housing Capital Fund Program (CFP) (Assistance Listing No. 14.872), for modernization projects, the Authority shall submit the Actual Modernization Cost Certificate (AMCC) (Form HUD-53001) and the final Performance & Evaluation Report (P&E) (HUD-50075.1) within 90 days after the Expenditure End Date (EED). Condition - The Authority did not submit the AMCC or P&E reports within 90 days after the EED for both MA01E035501-19 grant (EED - April 8, 2023) and MA01P035501-18 grant (EED - May 28, 2024). Cause - The delay in submission was due to ineffective internal controls over the closeout process of individual CFP grant years. Effect - Late submission or non-submission of the required reports could result in delayed reviews by HUD, potential penalties, and could affect the Authority’s eligibility for future funding. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is not a repeat finding. Recommendation - We recommend that the Authority enhance its internal controls to ensure timely submission of required reports. This could include implementing deadline tracking systems, providing additional training for staff responsible for report preparation, and establishing internal review processes to ensure compliance with reporting deadlines. Management’s Response - (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken. (b) Action taken - The Authority will implement controls to ensure all Capital Fund Program grants are accurately reported and finalized with HUD within the required due dates. (c) Planned implementation date of corrective action - Completed by March 31, 2025.
Criteria - According to HUD guidelines and Uniform Guidance (2 CFR 200.344) related to the Authority’s Public Housing Capital Fund Program (CFP) (Assistance Listing No. 14.872), for modernization projects, the Authority shall submit the Actual Modernization Cost Certificate (AMCC) (Form HUD-53001) and the final Performance & Evaluation Report (P&E) (HUD-50075.1) within 90 days after the Expenditure End Date (EED). Condition - The Authority did not submit the AMCC or P&E reports within 90 days after the EED for both MA01E035501-19 grant (EED - April 8, 2023) and MA01P035501-18 grant (EED - May 28, 2024). Cause - The delay in submission was due to ineffective internal controls over the closeout process of individual CFP grant years. Effect - Late submission or non-submission of the required reports could result in delayed reviews by HUD, potential penalties, and could affect the Authority’s eligibility for future funding. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is not a repeat finding. Recommendation - We recommend that the Authority enhance its internal controls to ensure timely submission of required reports. This could include implementing deadline tracking systems, providing additional training for staff responsible for report preparation, and establishing internal review processes to ensure compliance with reporting deadlines. Management’s Response - (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken. (b) Action taken - The Authority will implement controls to ensure all Capital Fund Program grants are accurately reported and finalized with HUD within the required due dates. (c) Planned implementation date of corrective action - Completed by March 31, 2025.
Criteria - According to HUD guidelines and Uniform Guidance (2 CFR 200.344) related to the Authority’s Public Housing Capital Fund Program (CFP) (Assistance Listing No. 14.872), final performance and financial reports are required to be submitted within 90 calendar days after the end of the period of performance. Condition - The Authority was unable to provide evidence that the required final performance and financial reports, including the HUD-50075.1 and HUD-53001, were completed within the 90-day period following the Disbursement End Date (August 15, 2023). As of the auditors’ opinion date, there is no evidence that the necessary reports were ever filed. Cause - The delay in submission was due to ineffective internal controls over the closeout process of individual CFP grant years. Effect - Late submission or non-submission of the required reports could result in delayed reviews by HUD, potential penalties, and could affect the Authority’s eligibility for future funding. Statistical Sampling - The sample weas not intended to be, and was not, a statistically valid sample. Questioned costs - None. Recommendation - We recommend that the Authority enhance its internal controls to ensure timely submission of required reports. This could include implementing deadline tracking systems, providing additional training for staff responsible for report preparation, and establishing internal review processes to ensure compliance with reporting deadlines. Management’s Response - (a) Comments on the finding and recommendation - The Authorit agrees with the finding. The Authority also agrees with the recommendation. Please see below for additional comments and action taken. (b) Action taken - The Authority will implement a comprehensive reporting calendar and tracking system, provide staff training on reporting requirements, establish an internal review and approval process for reports, conduct quarterly internal compliance audits, maintain regular communication with HUD, and continuously improve and document reporting processes with an annual review. These actions aim to ensure timely and accurate report submissions, thereby preventing future findings and maintaining eligibility for HUD funding. (c) Planned implementation date - The Authority plans to implement procedures during the fiscal year ending December 31, 2024 to resolve the reported finding.
FINDING 2023-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): ILBC-2023-Body Camera-00052 Pass-Through Entity: Indiana Department of Homeland Security Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 13 KOSCIUSKO COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The County Sheriff applied for the Indiana Local Body Camera Grant (ILBC). The grant is a reimbursable grant through the Indiana Department of Homeland Security. The County Sheriff was awarded this grant on January 1, 2023, with a grant cost amount of up to $31,920 to be spent from January 1, 2023 to December 31, 2023. The County Sheriff ordered body-worn cameras and other equipment on April 26, 2023. A Reimbursement Claim Form (Form) was submitted for the cameras and other equipment on September 11, 2023. The Form shows the County Sheriff requested the full $31,920; however, the County had only spent $9,581 from the grant fund towards the purchase. The reimbursement of $31,920 from the Indiana Department of Homeland Security was received on September 27, 2023. The fund had a balance of $22,339 as of December 31, 2023. As there are no grant expenditures for the remaining reimbursements received and the period of performance had ended, the County should have reimbursed the Indiana Department of Homeland Security $22,339. On May 9, 2023, the County Sheriff's grant administrator submitted a Program Report for the ILBC grant. The report was completed and submitted by the County Sheriff's grant administrator without a documented oversight or review process to ensure the completeness and accuracy of the report. The report incorrectly indicated that all expenditures had been completed. However, as of the date of the submission, the County had not purchased the body-worn cameras, and all federal funds had not been expended. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal 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). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." INDIANA STATE BOARD OF ACCOUNTS 14 KOSCIUSKO COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.344(d) states in part: "The non-Federal entity must promptly refund any balances of unobligated cash that the Federal awarding agency or pass-through entity paid in advance or paid and that are not authorized to be retained by the non-Federal entity for use in other projects. . . ." Cause A proper system of internal controls, which would include segregation of key functions, was not designed by management of the County to ensure the accuracy of the reimbursement invoice and the Program Report. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the County's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As such, federal reimbursement was requested in excess of the amount spent. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County establish a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place to ensure reimbursement invoices are complete and accurate prior to submission. Furthermore, we recommended the County contact the awarding agency to discuss the funds remaining. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
2023-014 Period of Performance Assistance Listing No.: 14.267 Continuum of Care Program Condition: The Organization was unable to demonstrate consistent controls over the period of performance requirement. Criteria: The requirements for the period of performance are contained in 2 CFR section 200.1 Definitions for “budget period,” “financial obligations,” “period of performance,” 2 CFR section 200.308 (revision of budget and program plans), 2 CFR section 200.309 (modifications to period of performance), 2 CFR section 200.344 (closeout), program legislation, federal awarding agency regulations; and the terms and conditions of the award. Questioned Costs There are no questioned costs. Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over. Effect: The Organization could have grant expenditures outside the grant period. Perspective: Thirty-one of forty items selected for testing did not have documentation of the control over compliance with the period of performance requirement. Repeat Finding: This is a repeat finding. See finding 2022-017. Recommendation: In order to prevent future occurences of this deficiency, we recommend that management expand controls to ensure that they are able to demonstrate that all expenses meet their procurement policy. Auditee's Response: The Organization agrees with the finding. See attached corrective action plan.
2023-014 Period of Performance Assistance Listing No.: 14.267 Continuum of Care Program Condition: The Organization was unable to demonstrate consistent controls over the period of performance requirement. Criteria: The requirements for the period of performance are contained in 2 CFR section 200.1 Definitions for “budget period,” “financial obligations,” “period of performance,” 2 CFR section 200.308 (revision of budget and program plans), 2 CFR section 200.309 (modifications to period of performance), 2 CFR section 200.344 (closeout), program legislation, federal awarding agency regulations; and the terms and conditions of the award. Questioned Costs There are no questioned costs. Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over. Effect: The Organization could have grant expenditures outside the grant period. Perspective: Thirty-one of forty items selected for testing did not have documentation of the control over compliance with the period of performance requirement. Repeat Finding: This is a repeat finding. See finding 2022-017. Recommendation: In order to prevent future occurences of this deficiency, we recommend that management expand controls to ensure that they are able to demonstrate that all expenses meet their procurement policy. Auditee's Response: The Organization agrees with the finding. See attached corrective action plan.
2023-014 Period of Performance Assistance Listing No.: 14.267 Continuum of Care Program Condition: The Organization was unable to demonstrate consistent controls over the period of performance requirement. Criteria: The requirements for the period of performance are contained in 2 CFR section 200.1 Definitions for “budget period,” “financial obligations,” “period of performance,” 2 CFR section 200.308 (revision of budget and program plans), 2 CFR section 200.309 (modifications to period of performance), 2 CFR section 200.344 (closeout), program legislation, federal awarding agency regulations; and the terms and conditions of the award. Questioned Costs There are no questioned costs. Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over. Effect: The Organization could have grant expenditures outside the grant period. Perspective: Thirty-one of forty items selected for testing did not have documentation of the control over compliance with the period of performance requirement. Repeat Finding: This is a repeat finding. See finding 2022-017. Recommendation: In order to prevent future occurences of this deficiency, we recommend that management expand controls to ensure that they are able to demonstrate that all expenses meet their procurement policy. Auditee's Response: The Organization agrees with the finding. See attached corrective action plan.
Criteria - According to HUD guidelines and Uniform Guidance (2 CFR 200.344) related to the Authority’s Public Housing Capital Fund Program (CFP) (Assistance Listing No. 14.872), final performance and financial reports are required to be submitted within 90 calendar days after the end of the period of performance. Condition - The Authority was unable to provide evidence that the required final performance and financial reports, including the HUD-50075.1 and HUD-53001, were completed within the 90-day period following the Disbursement End Date (August 15, 2023). As of the auditors’ opinion date, there is no evidence that the necessary reports were ever filed. Cause - The delay in submission was due to ineffective internal controls over the closeout process of individual CFP grant years. Effect - Late submission or non-submission of the required reports could result in delayed reviews by HUD, potential penalties, and could affect the Authority’s eligibility for future funding. Statistical Sampling - The sample weas not intended to be, and was not, a statistically valid sample. Questioned costs - None. Recommendation - We recommend that the Authority enhance its internal controls to ensure timely submission of required reports. This could include implementing deadline tracking systems, providing additional training for staff responsible for report preparation, and establishing internal review processes to ensure compliance with reporting deadlines. Management’s Response - (a) Comments on the finding and recommendation - The Authorit agrees with the finding. The Authority also agrees with the recommendation. Please see below for additional comments and action taken. (b) Action taken - The Authority will implement a comprehensive reporting calendar and tracking system, provide staff training on reporting requirements, establish an internal review and approval process for reports, conduct quarterly internal compliance audits, maintain regular communication with HUD, and continuously improve and document reporting processes with an annual review. These actions aim to ensure timely and accurate report submissions, thereby preventing future findings and maintaining eligibility for HUD funding. (c) Planned implementation date - The Authority plans to implement procedures during the fiscal year ending December 31, 2024 to resolve the reported finding.
FINDING 2023-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): ILBC-2023-Body Camera-00052 Pass-Through Entity: Indiana Department of Homeland Security Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 13 KOSCIUSKO COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The County Sheriff applied for the Indiana Local Body Camera Grant (ILBC). The grant is a reimbursable grant through the Indiana Department of Homeland Security. The County Sheriff was awarded this grant on January 1, 2023, with a grant cost amount of up to $31,920 to be spent from January 1, 2023 to December 31, 2023. The County Sheriff ordered body-worn cameras and other equipment on April 26, 2023. A Reimbursement Claim Form (Form) was submitted for the cameras and other equipment on September 11, 2023. The Form shows the County Sheriff requested the full $31,920; however, the County had only spent $9,581 from the grant fund towards the purchase. The reimbursement of $31,920 from the Indiana Department of Homeland Security was received on September 27, 2023. The fund had a balance of $22,339 as of December 31, 2023. As there are no grant expenditures for the remaining reimbursements received and the period of performance had ended, the County should have reimbursed the Indiana Department of Homeland Security $22,339. On May 9, 2023, the County Sheriff's grant administrator submitted a Program Report for the ILBC grant. The report was completed and submitted by the County Sheriff's grant administrator without a documented oversight or review process to ensure the completeness and accuracy of the report. The report incorrectly indicated that all expenditures had been completed. However, as of the date of the submission, the County had not purchased the body-worn cameras, and all federal funds had not been expended. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal 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). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." INDIANA STATE BOARD OF ACCOUNTS 14 KOSCIUSKO COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.344(d) states in part: "The non-Federal entity must promptly refund any balances of unobligated cash that the Federal awarding agency or pass-through entity paid in advance or paid and that are not authorized to be retained by the non-Federal entity for use in other projects. . . ." Cause A proper system of internal controls, which would include segregation of key functions, was not designed by management of the County to ensure the accuracy of the reimbursement invoice and the Program Report. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the County's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As such, federal reimbursement was requested in excess of the amount spent. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County establish a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place to ensure reimbursement invoices are complete and accurate prior to submission. Furthermore, we recommended the County contact the awarding agency to discuss the funds remaining. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: 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: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344. Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance. Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344. Questioned Costs: Known Questioned Costs Continuum of Care: $2,616 Likely Questioned Costs Continuum of Care: $435,898 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance. Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.