FINDING 2022-008 Subject: Title I Grants to Local Educational Agencies - Earmarking Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-008. Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Officials of the School Corporation were unaware that the earmarking requirement for Parental Involvement was a mandatory spending requirement. Therefore, there were no internal controls in place related to this requirement nor was the required amounts spent for parental involvement. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 37 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.400 states in part: ". . . (a) The non-Federal entity is responsible for the efficient and effective administration of the Federal award through the application of sound management practices. (b) The non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. . . ." 2 CFR 200.207 (Uniform Guidance) states in part: "The Federal Awarding Agency or pass-through entity may impose additional specific award conditions as needed . . ." 2 CFR 200.208(b) (Revised Uniform Guidance) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the earmarking requirements of the Matching, Level of Effort, and Earmarking compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-008 Subject: Title I Grants to Local Educational Agencies - Earmarking Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-008. Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Officials of the School Corporation were unaware that the earmarking requirement for Parental Involvement was a mandatory spending requirement. Therefore, there were no internal controls in place related to this requirement nor was the required amounts spent for parental involvement. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 37 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.400 states in part: ". . . (a) The non-Federal entity is responsible for the efficient and effective administration of the Federal award through the application of sound management practices. (b) The non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. . . ." 2 CFR 200.207 (Uniform Guidance) states in part: "The Federal Awarding Agency or pass-through entity may impose additional specific award conditions as needed . . ." 2 CFR 200.208(b) (Revised Uniform Guidance) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the earmarking requirements of the Matching, Level of Effort, and Earmarking compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Child Nutrition Cluster ?School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-005 ? Significant Deficiency in Controls over Compliance and Compliance Finding: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding 2021-006 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management, procurement and compensation are in need of adoption and enhancement to meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: The Catholic Secondary Schools of the Diocese of Grand Rapids have limited written policies and procedures that are applicable to federal awards and address the direct and material compliance matters important to the major federal program. In addition, there are unique policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that are relevant to the Schools? federal programs. Recommendations: The Catholic Secondary Schools of the Diocese of Grand Rapids should adopt the following written policies and updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Schools ensure compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 ? 200.326) The Schools must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320. ? Policy Guide (2 CFR 200.400) In summary, the Schools must have written policies that document the efficient and effective administration of federal awards through sound management practices. The Schools have the primary responsibility for employing whatever form of sound organization and management techniques may be necessary to assure proper and efficient administration of the federal awards. The accounting practices must be consistent with Uniform Guidance cost principles, support the accumulation of costs as required, and must provide for adequate documentation to support costs charged to the federal award. Views of Responsible Officials and Planned Corrective Actions: Child Nutrition Cluster ?School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-005 ? Significant Deficiency in Controls over Compliance and Compliance Finding: Administrative Requirements of Uniform Guidance ? Administrative Policies This is also a compliance finding, not just controls - UPDATED This is a repeat of prior year finding 2021-006 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management, procurement and compensation are in need of adoption and enhancement to meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: The Catholic Secondary Schools of the Diocese of Grand Rapids have limited written policies and procedures that are applicable to federal awards and address the direct and material compliance matters important to the major federal program. In addition, there are unique policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that are relevant to the Schools? federal programs. Recommendations: The Catholic Secondary Schools of the Diocese of Grand Rapids should adopt the following written policies and updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Schools ensure compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 ? 200.326) The Schools must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320. ? Policy Guide (2 CFR 200.400) In summary, the Schools must have written policies that document the efficient and effective administration of federal awards through sound management practices. The Schools have the primary responsibility for employing whatever form of sound organization and management techniques may be necessary to assure proper and efficient administration of the federal awards. The accounting practices must be consistent with Uniform Guidance cost principles, support the accumulation of costs as required, and must provide for adequate documentation to support costs charged to the federal award. Views of Responsible Officials and Planned Corrective Actions: We concur with the findings of the auditors. We have developed a plan to address the findings, and are actively working to implement that plan. The corrective action plan is attached to this report.
Child Nutrition Cluster ?School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-005 ? Significant Deficiency in Controls over Compliance and Compliance Finding: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding 2021-006 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management, procurement and compensation are in need of adoption and enhancement to meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: The Catholic Secondary Schools of the Diocese of Grand Rapids have limited written policies and procedures that are applicable to federal awards and address the direct and material compliance matters important to the major federal program. In addition, there are unique policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that are relevant to the Schools? federal programs. Recommendations: The Catholic Secondary Schools of the Diocese of Grand Rapids should adopt the following written policies and updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Schools ensure compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 ? 200.326) The Schools must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320. ? Policy Guide (2 CFR 200.400) In summary, the Schools must have written policies that document the efficient and effective administration of federal awards through sound management practices. The Schools have the primary responsibility for employing whatever form of sound organization and management techniques may be necessary to assure proper and efficient administration of the federal awards. The accounting practices must be consistent with Uniform Guidance cost principles, support the accumulation of costs as required, and must provide for adequate documentation to support costs charged to the federal award. Views of Responsible Officials and Planned Corrective Actions: Child Nutrition Cluster ?School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-005 ? Significant Deficiency in Controls over Compliance and Compliance Finding: Administrative Requirements of Uniform Guidance ? Administrative Policies This is also a compliance finding, not just controls - UPDATED This is a repeat of prior year finding 2021-006 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management, procurement and compensation are in need of adoption and enhancement to meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: The Catholic Secondary Schools of the Diocese of Grand Rapids have limited written policies and procedures that are applicable to federal awards and address the direct and material compliance matters important to the major federal program. In addition, there are unique policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that are relevant to the Schools? federal programs. Recommendations: The Catholic Secondary Schools of the Diocese of Grand Rapids should adopt the following written policies and updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Schools ensure compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 ? 200.326) The Schools must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320. ? Policy Guide (2 CFR 200.400) In summary, the Schools must have written policies that document the efficient and effective administration of federal awards through sound management practices. The Schools have the primary responsibility for employing whatever form of sound organization and management techniques may be necessary to assure proper and efficient administration of the federal awards. The accounting practices must be consistent with Uniform Guidance cost principles, support the accumulation of costs as required, and must provide for adequate documentation to support costs charged to the federal award. Views of Responsible Officials and Planned Corrective Actions: We concur with the findings of the auditors. We have developed a plan to address the findings, and are actively working to implement that plan. The corrective action plan is attached to this report.
FINDING 2022-007Subject: Title I Grants to Local Education Agencies - EarmarkingFederal Agency: Department of EducationFederal Program: Title I Grants to Local Educational AgenciesAssistance Listings Number: 84.010Federal Award Numbers and Years (or Other Identifying Numbers): FY19, FY 20Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Matching, Level of Effort, EarmarkingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Matching, Level of Effort, Earmarkingcompliance requirement.Officials of the School Corporation did not properly monitor the Homeless set-aside to ensureamounts were tracked for those students designated as homeless. For the Title I grant years FY19 andFY20, the entire Homeless set-aside of $1,632 and $550, respectively, was not spent. In addition, the setasideswere not carried forward for subsequent year expenses.The lack of internal controls and noncompliance were systemic issues throughout the audit period.INDIANA STATE BOARD OF ACCOUNTS27BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The Non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.400 states in part:"(a) The non-Federal entity is responsible for the efficient and effective administration of theFederal award through the application of sound management practices.(b) The non-Federal entity assumes responsibility for administering Federal funds in a mannerconsistent with underlying agreements, program objectives, and the terms and conditions ofthe Federal award. . . ."20 USC 6313(c)(3) states in part:"(A) In General. A local educational agency shall reserve such funds as are necessary underthis part, determined in accordance with subparagraphs (B) and (C), to provide servicescomparable to those provided to children in schools funded under this part to serve?(i) homeless children and youths, including providing educationally related supportservices to children in shelters and other locations where children may live;(ii) children in local institutions for neglected children; and(iii) if appropriate, children in local institutions for delinquent children, and neglected ordelinquent children in community day programs. . . .(C) Homeless children and youths. Funds reserved under subparagraph (A)(i) may be? . . .(ii) used to provide homeless children and youths with services not ordinarily provided toother students under this part, including providing?(I) funding for the liaison designated pursuant to section 11432(g)(1)(J)(ii) of title 42;and(II) transportation pursuant to section 11432(g)(1)(J)(iii) of such title."CauseManagement had not established an effective system of internal controls that would have ensuredcompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement.INDIANA STATE BOARD OF ACCOUNTS28BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)EffectThe failure to establish an effective system of internal controls enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls related tothe grant agreement and the Matching, Level of Effort, Earmarking compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-007Subject: Title I Grants to Local Education Agencies - EarmarkingFederal Agency: Department of EducationFederal Program: Title I Grants to Local Educational AgenciesAssistance Listings Number: 84.010Federal Award Numbers and Years (or Other Identifying Numbers): FY19, FY 20Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Matching, Level of Effort, EarmarkingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Matching, Level of Effort, Earmarkingcompliance requirement.Officials of the School Corporation did not properly monitor the Homeless set-aside to ensureamounts were tracked for those students designated as homeless. For the Title I grant years FY19 andFY20, the entire Homeless set-aside of $1,632 and $550, respectively, was not spent. In addition, the setasideswere not carried forward for subsequent year expenses.The lack of internal controls and noncompliance were systemic issues throughout the audit period.INDIANA STATE BOARD OF ACCOUNTS27BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The Non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.400 states in part:"(a) The non-Federal entity is responsible for the efficient and effective administration of theFederal award through the application of sound management practices.(b) The non-Federal entity assumes responsibility for administering Federal funds in a mannerconsistent with underlying agreements, program objectives, and the terms and conditions ofthe Federal award. . . ."20 USC 6313(c)(3) states in part:"(A) In General. A local educational agency shall reserve such funds as are necessary underthis part, determined in accordance with subparagraphs (B) and (C), to provide servicescomparable to those provided to children in schools funded under this part to serve?(i) homeless children and youths, including providing educationally related supportservices to children in shelters and other locations where children may live;(ii) children in local institutions for neglected children; and(iii) if appropriate, children in local institutions for delinquent children, and neglected ordelinquent children in community day programs. . . .(C) Homeless children and youths. Funds reserved under subparagraph (A)(i) may be? . . .(ii) used to provide homeless children and youths with services not ordinarily provided toother students under this part, including providing?(I) funding for the liaison designated pursuant to section 11432(g)(1)(J)(ii) of title 42;and(II) transportation pursuant to section 11432(g)(1)(J)(iii) of such title."CauseManagement had not established an effective system of internal controls that would have ensuredcompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement.INDIANA STATE BOARD OF ACCOUNTS28BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)EffectThe failure to establish an effective system of internal controls enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls related tothe grant agreement and the Matching, Level of Effort, Earmarking compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2021-003: Material Weakness and Questioned Cost – Grant Claim Support Federal grantor: Department of Commerce Condition: The Chamber’s expenditure detail for the grant funded projects do not support the amounts billed to the Department of Commerce. The amounts billed were more than the general ledger detail supported. Criteria: A reconciliation of grant project expenses to the grant revenue billed should be performed. The supporting documentation of any reconciling items should be maintained with the grant bills. Also, 2 CFR 200.400 states that accounting practices of the entity be consistent with cost principals required under the CFR and support the accumulation of costs and provide adequate documentation to support costs charged to the Federal award. Cause: The Chamber billed costs to the grant that were not allocated in the accounting system to that grant and a reconciliation was not performed comparing the grant billings to the expense detail. Effect: The expenses billed to the grant may not be correct. Our reconciliation of these expenses disclosed an overbilling to the grant of approximately $2,500. Recommendation: The Chamber needs to ensure that expenses to be reimbursed by federal grant funds are recorded in the class code in the accounting system for that grant so that federal grant revenue in the accounting system match the expenses allocated to that grant. The Chamber needs to include in their year-end reconciliations a comparison of grant revenue and expense and ensure they match or can be reconciled. Management’s Response: Management’s response to the finding is discussed in the Corrective Action Plan.
Finding 2021-004: Significant Deficiency – Grant Claim Support Federal grantor: Department of Commerce Condition: The allocation of payroll costs to programs are done manually using spreadsheets instead of done based on entity-wide timesheets. Criteria: Under 2 CFR 200.400, direct cost allocation principles state that if a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Further, a cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. Costs are required to be adequately documented. Cause: The Chamber is not able to readily determine the amount of payroll costs billable to the grants. Effect: The approach of manually allocating payroll costs to grant projects leaves room for error, and makes it difficult to determine that costs are not being reimbursed by more than one source. Recommendation: The Chamber needs to prepare time studies or require employees to prepare timesheets on an automated system to support the payroll costs allocated to programs. Management’s Response: Management’s response to the finding is discussed in the Corrective Action Plan.
Finding 2021-004: Material Weakness Due to Unsupported Administration and Program Operations Costs Federal Agency: U.S. Department of Treasury Program Title: Emergency Rental Assistance Program and Corona Virus Relief Fund Assistance Listing Numbers (ALN): 21.023 and 21.019 Federal Award Years: Year ended December 31, 2023 Pass-through Grantor and identifying numbers: Pierce County; SC-108112, SC-108282, SC-108719, SC- 108080 Criteria: Charges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles. Specifically CFR 200.400(d) indicates the Organization must support the accumulation of costs and provide for adequate documentation to support costs charged to the Federal award. Condition and Context: Administration and program operation costs charged to the award for the period ended December 31, 2021 lacked supporting documentation to verify whether there were equivalent administrative and program operation expenses incurred by the Organization. All budgets approved by the Pass-through Grantor allowed for such costs to be reimbursed by the award as long as adequate documentation of how the costs were determined was retained. Since the organization did not retain any such documentation, there is no way of knowing if a portion or all of those administration or program operation costs related to actual activities that were performed related to these programs. The Organization most certainly did incur administration and program operation costs that were legitimate to be remitted to the award. However, with no controls in place to ensure that these costs were appropriately accumulated and documented, the amounts reimbursed by the programs might not be appropriate. During our audit, we were able to fully quantify the full amount of administration and program operations costs that were inappropriately supported through discussions with management of the Organization and reviewing the reimbursement requests that were submitted to the Pass-through Grantor. The amounts included in the questioned costs below is the entire amount of such costs that were charged to the program during the year ended December 31, 2021. Cause: Helping Hand House did not have processes and controls in place to ensure that documentation to ensure that administrative and program operation costs that were charged to the program were appropriately documented. Effect: There is the potential that the Pass-through grantor may require a repayment of a portion or all of the program and administrative costs that were paid for by the program. As such, a loss contingency disclosure has been included in the notes to the financial statements to indicate that there is the potential that the Pass-through Grantor may require some of these amounts to be repaid. This also is the reason for the qualified opinion in the Report On Compliance for Each Major Federal Program. Known Questioned Costs for ALN 21.023: $329,572 Known Questioned Costs for ALN 21.019: $164,757 Repeat Finding: Not applicable. Recommendation: We recommend that Helping Hand House develop and document procedures and controls for how administrative and program operation costs will be allocated to the federal awards. This information should be retained so that it can be made available at the request of the Pass-through Grantor, the auditor or other relevant parties. Views of Responsible Official: See Corrective Action Plan.
Finding 2021-004: Material Weakness Due to Unsupported Administration and Program Operations Costs Federal Agency: U.S. Department of Treasury Program Title: Emergency Rental Assistance Program and Corona Virus Relief Fund Assistance Listing Numbers (ALN): 21.023 and 21.019 Federal Award Years: Year ended December 31, 2023 Pass-through Grantor and identifying numbers: Pierce County; SC-108112, SC-108282, SC-108719, SC- 108080 Criteria: Charges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles. Specifically CFR 200.400(d) indicates the Organization must support the accumulation of costs and provide for adequate documentation to support costs charged to the Federal award. Condition and Context: Administration and program operation costs charged to the award for the period ended December 31, 2021 lacked supporting documentation to verify whether there were equivalent administrative and program operation expenses incurred by the Organization. All budgets approved by the Pass-through Grantor allowed for such costs to be reimbursed by the award as long as adequate documentation of how the costs were determined was retained. Since the organization did not retain any such documentation, there is no way of knowing if a portion or all of those administration or program operation costs related to actual activities that were performed related to these programs. The Organization most certainly did incur administration and program operation costs that were legitimate to be remitted to the award. However, with no controls in place to ensure that these costs were appropriately accumulated and documented, the amounts reimbursed by the programs might not be appropriate. During our audit, we were able to fully quantify the full amount of administration and program operations costs that were inappropriately supported through discussions with management of the Organization and reviewing the reimbursement requests that were submitted to the Pass-through Grantor. The amounts included in the questioned costs below is the entire amount of such costs that were charged to the program during the year ended December 31, 2021. Cause: Helping Hand House did not have processes and controls in place to ensure that documentation to ensure that administrative and program operation costs that were charged to the program were appropriately documented. Effect: There is the potential that the Pass-through grantor may require a repayment of a portion or all of the program and administrative costs that were paid for by the program. As such, a loss contingency disclosure has been included in the notes to the financial statements to indicate that there is the potential that the Pass-through Grantor may require some of these amounts to be repaid. This also is the reason for the qualified opinion in the Report On Compliance for Each Major Federal Program. Known Questioned Costs for ALN 21.023: $329,572 Known Questioned Costs for ALN 21.019: $164,757 Repeat Finding: Not applicable. Recommendation: We recommend that Helping Hand House develop and document procedures and controls for how administrative and program operation costs will be allocated to the federal awards. This information should be retained so that it can be made available at the request of the Pass-through Grantor, the auditor or other relevant parties. Views of Responsible Official: See Corrective Action Plan.
Finding 2021-004: Material Weakness Due to Unsupported Administration and Program Operations Costs Federal Agency: U.S. Department of Treasury Program Title: Emergency Rental Assistance Program and Corona Virus Relief Fund Assistance Listing Numbers (ALN): 21.023 and 21.019 Federal Award Years: Year ended December 31, 2023 Pass-through Grantor and identifying numbers: Pierce County; SC-108112, SC-108282, SC-108719, SC- 108080 Criteria: Charges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles. Specifically CFR 200.400(d) indicates the Organization must support the accumulation of costs and provide for adequate documentation to support costs charged to the Federal award. Condition and Context: Administration and program operation costs charged to the award for the period ended December 31, 2021 lacked supporting documentation to verify whether there were equivalent administrative and program operation expenses incurred by the Organization. All budgets approved by the Pass-through Grantor allowed for such costs to be reimbursed by the award as long as adequate documentation of how the costs were determined was retained. Since the organization did not retain any such documentation, there is no way of knowing if a portion or all of those administration or program operation costs related to actual activities that were performed related to these programs. The Organization most certainly did incur administration and program operation costs that were legitimate to be remitted to the award. However, with no controls in place to ensure that these costs were appropriately accumulated and documented, the amounts reimbursed by the programs might not be appropriate. During our audit, we were able to fully quantify the full amount of administration and program operations costs that were inappropriately supported through discussions with management of the Organization and reviewing the reimbursement requests that were submitted to the Pass-through Grantor. The amounts included in the questioned costs below is the entire amount of such costs that were charged to the program during the year ended December 31, 2021. Cause: Helping Hand House did not have processes and controls in place to ensure that documentation to ensure that administrative and program operation costs that were charged to the program were appropriately documented. Effect: There is the potential that the Pass-through grantor may require a repayment of a portion or all of the program and administrative costs that were paid for by the program. As such, a loss contingency disclosure has been included in the notes to the financial statements to indicate that there is the potential that the Pass-through Grantor may require some of these amounts to be repaid. This also is the reason for the qualified opinion in the Report On Compliance for Each Major Federal Program. Known Questioned Costs for ALN 21.023: $329,572 Known Questioned Costs for ALN 21.019: $164,757 Repeat Finding: Not applicable. Recommendation: We recommend that Helping Hand House develop and document procedures and controls for how administrative and program operation costs will be allocated to the federal awards. This information should be retained so that it can be made available at the request of the Pass-through Grantor, the auditor or other relevant parties. Views of Responsible Official: See Corrective Action Plan.
Finding 2021-004: Material Weakness Due to Unsupported Administration and Program Operations Costs Federal Agency: U.S. Department of Treasury Program Title: Emergency Rental Assistance Program and Corona Virus Relief Fund Assistance Listing Numbers (ALN): 21.023 and 21.019 Federal Award Years: Year ended December 31, 2023 Pass-through Grantor and identifying numbers: Pierce County; SC-108112, SC-108282, SC-108719, SC- 108080 Criteria: Charges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles. Specifically CFR 200.400(d) indicates the Organization must support the accumulation of costs and provide for adequate documentation to support costs charged to the Federal award. Condition and Context: Administration and program operation costs charged to the award for the period ended December 31, 2021 lacked supporting documentation to verify whether there were equivalent administrative and program operation expenses incurred by the Organization. All budgets approved by the Pass-through Grantor allowed for such costs to be reimbursed by the award as long as adequate documentation of how the costs were determined was retained. Since the organization did not retain any such documentation, there is no way of knowing if a portion or all of those administration or program operation costs related to actual activities that were performed related to these programs. The Organization most certainly did incur administration and program operation costs that were legitimate to be remitted to the award. However, with no controls in place to ensure that these costs were appropriately accumulated and documented, the amounts reimbursed by the programs might not be appropriate. During our audit, we were able to fully quantify the full amount of administration and program operations costs that were inappropriately supported through discussions with management of the Organization and reviewing the reimbursement requests that were submitted to the Pass-through Grantor. The amounts included in the questioned costs below is the entire amount of such costs that were charged to the program during the year ended December 31, 2021. Cause: Helping Hand House did not have processes and controls in place to ensure that documentation to ensure that administrative and program operation costs that were charged to the program were appropriately documented. Effect: There is the potential that the Pass-through grantor may require a repayment of a portion or all of the program and administrative costs that were paid for by the program. As such, a loss contingency disclosure has been included in the notes to the financial statements to indicate that there is the potential that the Pass-through Grantor may require some of these amounts to be repaid. This also is the reason for the qualified opinion in the Report On Compliance for Each Major Federal Program. Known Questioned Costs for ALN 21.023: $329,572 Known Questioned Costs for ALN 21.019: $164,757 Repeat Finding: Not applicable. Recommendation: We recommend that Helping Hand House develop and document procedures and controls for how administrative and program operation costs will be allocated to the federal awards. This information should be retained so that it can be made available at the request of the Pass-through Grantor, the auditor or other relevant parties. Views of Responsible Official: See Corrective Action Plan.
Finding 2021-003: Material Weakness and Questioned Cost – Grant Claim Support Federal grantor: Department of Commerce Condition: The Chamber’s expenditure detail for the grant funded projects do not support the amounts billed to the Department of Commerce. The amounts billed were more than the general ledger detail supported. Criteria: A reconciliation of grant project expenses to the grant revenue billed should be performed. The supporting documentation of any reconciling items should be maintained with the grant bills. Also, 2 CFR 200.400 states that accounting practices of the entity be consistent with cost principals required under the CFR and support the accumulation of costs and provide adequate documentation to support costs charged to the Federal award. Cause: The Chamber billed costs to the grant that were not allocated in the accounting system to that grant and a reconciliation was not performed comparing the grant billings to the expense detail. Effect: The expenses billed to the grant may not be correct. Our reconciliation of these expenses disclosed an overbilling to the grant of approximately $2,500. Recommendation: The Chamber needs to ensure that expenses to be reimbursed by federal grant funds are recorded in the class code in the accounting system for that grant so that federal grant revenue in the accounting system match the expenses allocated to that grant. The Chamber needs to include in their year-end reconciliations a comparison of grant revenue and expense and ensure they match or can be reconciled. Management’s Response: Management’s response to the finding is discussed in the Corrective Action Plan.
Finding 2021-004: Significant Deficiency – Grant Claim Support Federal grantor: Department of Commerce Condition: The allocation of payroll costs to programs are done manually using spreadsheets instead of done based on entity-wide timesheets. Criteria: Under 2 CFR 200.400, direct cost allocation principles state that if a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Further, a cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. Costs are required to be adequately documented. Cause: The Chamber is not able to readily determine the amount of payroll costs billable to the grants. Effect: The approach of manually allocating payroll costs to grant projects leaves room for error, and makes it difficult to determine that costs are not being reimbursed by more than one source. Recommendation: The Chamber needs to prepare time studies or require employees to prepare timesheets on an automated system to support the payroll costs allocated to programs. Management’s Response: Management’s response to the finding is discussed in the Corrective Action Plan.
Finding 2021-004: Material Weakness Due to Unsupported Administration and Program Operations Costs Federal Agency: U.S. Department of Treasury Program Title: Emergency Rental Assistance Program and Corona Virus Relief Fund Assistance Listing Numbers (ALN): 21.023 and 21.019 Federal Award Years: Year ended December 31, 2023 Pass-through Grantor and identifying numbers: Pierce County; SC-108112, SC-108282, SC-108719, SC- 108080 Criteria: Charges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles. Specifically CFR 200.400(d) indicates the Organization must support the accumulation of costs and provide for adequate documentation to support costs charged to the Federal award. Condition and Context: Administration and program operation costs charged to the award for the period ended December 31, 2021 lacked supporting documentation to verify whether there were equivalent administrative and program operation expenses incurred by the Organization. All budgets approved by the Pass-through Grantor allowed for such costs to be reimbursed by the award as long as adequate documentation of how the costs were determined was retained. Since the organization did not retain any such documentation, there is no way of knowing if a portion or all of those administration or program operation costs related to actual activities that were performed related to these programs. The Organization most certainly did incur administration and program operation costs that were legitimate to be remitted to the award. However, with no controls in place to ensure that these costs were appropriately accumulated and documented, the amounts reimbursed by the programs might not be appropriate. During our audit, we were able to fully quantify the full amount of administration and program operations costs that were inappropriately supported through discussions with management of the Organization and reviewing the reimbursement requests that were submitted to the Pass-through Grantor. The amounts included in the questioned costs below is the entire amount of such costs that were charged to the program during the year ended December 31, 2021. Cause: Helping Hand House did not have processes and controls in place to ensure that documentation to ensure that administrative and program operation costs that were charged to the program were appropriately documented. Effect: There is the potential that the Pass-through grantor may require a repayment of a portion or all of the program and administrative costs that were paid for by the program. As such, a loss contingency disclosure has been included in the notes to the financial statements to indicate that there is the potential that the Pass-through Grantor may require some of these amounts to be repaid. This also is the reason for the qualified opinion in the Report On Compliance for Each Major Federal Program. Known Questioned Costs for ALN 21.023: $329,572 Known Questioned Costs for ALN 21.019: $164,757 Repeat Finding: Not applicable. Recommendation: We recommend that Helping Hand House develop and document procedures and controls for how administrative and program operation costs will be allocated to the federal awards. This information should be retained so that it can be made available at the request of the Pass-through Grantor, the auditor or other relevant parties. Views of Responsible Official: See Corrective Action Plan.
Finding 2021-004: Material Weakness Due to Unsupported Administration and Program Operations Costs Federal Agency: U.S. Department of Treasury Program Title: Emergency Rental Assistance Program and Corona Virus Relief Fund Assistance Listing Numbers (ALN): 21.023 and 21.019 Federal Award Years: Year ended December 31, 2023 Pass-through Grantor and identifying numbers: Pierce County; SC-108112, SC-108282, SC-108719, SC- 108080 Criteria: Charges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles. Specifically CFR 200.400(d) indicates the Organization must support the accumulation of costs and provide for adequate documentation to support costs charged to the Federal award. Condition and Context: Administration and program operation costs charged to the award for the period ended December 31, 2021 lacked supporting documentation to verify whether there were equivalent administrative and program operation expenses incurred by the Organization. All budgets approved by the Pass-through Grantor allowed for such costs to be reimbursed by the award as long as adequate documentation of how the costs were determined was retained. Since the organization did not retain any such documentation, there is no way of knowing if a portion or all of those administration or program operation costs related to actual activities that were performed related to these programs. The Organization most certainly did incur administration and program operation costs that were legitimate to be remitted to the award. However, with no controls in place to ensure that these costs were appropriately accumulated and documented, the amounts reimbursed by the programs might not be appropriate. During our audit, we were able to fully quantify the full amount of administration and program operations costs that were inappropriately supported through discussions with management of the Organization and reviewing the reimbursement requests that were submitted to the Pass-through Grantor. The amounts included in the questioned costs below is the entire amount of such costs that were charged to the program during the year ended December 31, 2021. Cause: Helping Hand House did not have processes and controls in place to ensure that documentation to ensure that administrative and program operation costs that were charged to the program were appropriately documented. Effect: There is the potential that the Pass-through grantor may require a repayment of a portion or all of the program and administrative costs that were paid for by the program. As such, a loss contingency disclosure has been included in the notes to the financial statements to indicate that there is the potential that the Pass-through Grantor may require some of these amounts to be repaid. This also is the reason for the qualified opinion in the Report On Compliance for Each Major Federal Program. Known Questioned Costs for ALN 21.023: $329,572 Known Questioned Costs for ALN 21.019: $164,757 Repeat Finding: Not applicable. Recommendation: We recommend that Helping Hand House develop and document procedures and controls for how administrative and program operation costs will be allocated to the federal awards. This information should be retained so that it can be made available at the request of the Pass-through Grantor, the auditor or other relevant parties. Views of Responsible Official: See Corrective Action Plan.
Finding 2021-004: Material Weakness Due to Unsupported Administration and Program Operations Costs Federal Agency: U.S. Department of Treasury Program Title: Emergency Rental Assistance Program and Corona Virus Relief Fund Assistance Listing Numbers (ALN): 21.023 and 21.019 Federal Award Years: Year ended December 31, 2023 Pass-through Grantor and identifying numbers: Pierce County; SC-108112, SC-108282, SC-108719, SC- 108080 Criteria: Charges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles. Specifically CFR 200.400(d) indicates the Organization must support the accumulation of costs and provide for adequate documentation to support costs charged to the Federal award. Condition and Context: Administration and program operation costs charged to the award for the period ended December 31, 2021 lacked supporting documentation to verify whether there were equivalent administrative and program operation expenses incurred by the Organization. All budgets approved by the Pass-through Grantor allowed for such costs to be reimbursed by the award as long as adequate documentation of how the costs were determined was retained. Since the organization did not retain any such documentation, there is no way of knowing if a portion or all of those administration or program operation costs related to actual activities that were performed related to these programs. The Organization most certainly did incur administration and program operation costs that were legitimate to be remitted to the award. However, with no controls in place to ensure that these costs were appropriately accumulated and documented, the amounts reimbursed by the programs might not be appropriate. During our audit, we were able to fully quantify the full amount of administration and program operations costs that were inappropriately supported through discussions with management of the Organization and reviewing the reimbursement requests that were submitted to the Pass-through Grantor. The amounts included in the questioned costs below is the entire amount of such costs that were charged to the program during the year ended December 31, 2021. Cause: Helping Hand House did not have processes and controls in place to ensure that documentation to ensure that administrative and program operation costs that were charged to the program were appropriately documented. Effect: There is the potential that the Pass-through grantor may require a repayment of a portion or all of the program and administrative costs that were paid for by the program. As such, a loss contingency disclosure has been included in the notes to the financial statements to indicate that there is the potential that the Pass-through Grantor may require some of these amounts to be repaid. This also is the reason for the qualified opinion in the Report On Compliance for Each Major Federal Program. Known Questioned Costs for ALN 21.023: $329,572 Known Questioned Costs for ALN 21.019: $164,757 Repeat Finding: Not applicable. Recommendation: We recommend that Helping Hand House develop and document procedures and controls for how administrative and program operation costs will be allocated to the federal awards. This information should be retained so that it can be made available at the request of the Pass-through Grantor, the auditor or other relevant parties. Views of Responsible Official: See Corrective Action Plan.
Finding 2021-004: Material Weakness Due to Unsupported Administration and Program Operations Costs Federal Agency: U.S. Department of Treasury Program Title: Emergency Rental Assistance Program and Corona Virus Relief Fund Assistance Listing Numbers (ALN): 21.023 and 21.019 Federal Award Years: Year ended December 31, 2023 Pass-through Grantor and identifying numbers: Pierce County; SC-108112, SC-108282, SC-108719, SC- 108080 Criteria: Charges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles. Specifically CFR 200.400(d) indicates the Organization must support the accumulation of costs and provide for adequate documentation to support costs charged to the Federal award. Condition and Context: Administration and program operation costs charged to the award for the period ended December 31, 2021 lacked supporting documentation to verify whether there were equivalent administrative and program operation expenses incurred by the Organization. All budgets approved by the Pass-through Grantor allowed for such costs to be reimbursed by the award as long as adequate documentation of how the costs were determined was retained. Since the organization did not retain any such documentation, there is no way of knowing if a portion or all of those administration or program operation costs related to actual activities that were performed related to these programs. The Organization most certainly did incur administration and program operation costs that were legitimate to be remitted to the award. However, with no controls in place to ensure that these costs were appropriately accumulated and documented, the amounts reimbursed by the programs might not be appropriate. During our audit, we were able to fully quantify the full amount of administration and program operations costs that were inappropriately supported through discussions with management of the Organization and reviewing the reimbursement requests that were submitted to the Pass-through Grantor. The amounts included in the questioned costs below is the entire amount of such costs that were charged to the program during the year ended December 31, 2021. Cause: Helping Hand House did not have processes and controls in place to ensure that documentation to ensure that administrative and program operation costs that were charged to the program were appropriately documented. Effect: There is the potential that the Pass-through grantor may require a repayment of a portion or all of the program and administrative costs that were paid for by the program. As such, a loss contingency disclosure has been included in the notes to the financial statements to indicate that there is the potential that the Pass-through Grantor may require some of these amounts to be repaid. This also is the reason for the qualified opinion in the Report On Compliance for Each Major Federal Program. Known Questioned Costs for ALN 21.023: $329,572 Known Questioned Costs for ALN 21.019: $164,757 Repeat Finding: Not applicable. Recommendation: We recommend that Helping Hand House develop and document procedures and controls for how administrative and program operation costs will be allocated to the federal awards. This information should be retained so that it can be made available at the request of the Pass-through Grantor, the auditor or other relevant parties. Views of Responsible Official: See Corrective Action Plan.