Criteria or specific requirement: According to § 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to § 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to § 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to § 200.430 Compensation—personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, when applicable. According to § 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: None Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Repeat Finding: This audit finding was reported in the prior year in finding 2022-002. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
Criteria or specific requirement: According to § 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to § 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to § 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to § 200.430 Compensation—personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, when applicable. According to § 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: None Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Repeat Finding: This audit finding was reported in the prior year in finding 2022-002. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
Criteria or specific requirement: According to § 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to § 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to § 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to § 200.430 Compensation—personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, when applicable. According to § 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: None Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Repeat Finding: This audit finding was reported in the prior year in finding 2022-002. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
Criteria or specific requirement: According to § 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to § 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to § 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to § 200.430 Compensation—personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, when applicable. According to § 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: None Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Repeat Finding: This audit finding was reported in the prior year in finding 2022-002. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
Criteria or specific requirement: According to § 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to § 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to § 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to § 200.430 Compensation—personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, when applicable. According to § 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: None Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Repeat Finding: This audit finding was reported in the prior year in finding 2022-002. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
Criteria or specific requirement: According to § 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to § 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to § 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to § 200.430 Compensation—personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, when applicable. According to § 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: None Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Repeat Finding: This audit finding was reported in the prior year in finding 2022-002. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
Criteria or specific requirement: According to § 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to § 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to § 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to § 200.430 Compensation—personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, when applicable. According to § 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: None Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Repeat Finding: This audit finding was reported in the prior year in finding 2022-002. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
Criteria or specific requirement: According to § 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to § 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to § 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to § 200.430 Compensation—personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, when applicable. According to § 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: None Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Repeat Finding: This audit finding was reported in the prior year in finding 2022-002. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
Criteria or specific requirement: According to § 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to § 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to § 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to § 200.430 Compensation—personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, when applicable. According to § 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: None Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Repeat Finding: This audit finding was reported in the prior year in finding 2022-002. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
Criteria or specific requirement: According to § 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to § 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to § 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to § 200.430 Compensation—personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, when applicable. According to § 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: None Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Repeat Finding: This audit finding was reported in the prior year in finding 2022-002. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
Criteria or specific requirement: According to § 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to § 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to § 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to § 200.430 Compensation—personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, when applicable. According to § 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: None Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Repeat Finding: This audit finding was reported in the prior year in finding 2022-002. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
Criteria or specific requirement: According to § 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to § 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to § 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to § 200.430 Compensation—personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, when applicable. According to § 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: None Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Repeat Finding: This audit finding was reported in the prior year in finding 2022-002. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
Criteria or specific requirement: According to § 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to § 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to § 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to § 200.430 Compensation—personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; (2) Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, when applicable. According to § 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: None Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Repeat Finding: This audit finding was reported in the prior year in finding 2022-002. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Opioid Response Grants Assistance Listing Number: 93.788 Federal Award Identification Number: H79TI083278 Pass-Through Entity: Illinois Department of Human Services Pass-Through Number: 43CBC03525 Award Periods: July 1, 2022 – June 30, 2023 Criteria: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award's period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Costs incurred outside of the period of performance were charged to the grant. Questioned Costs: $26,230 Context: Six of eighteen transactions selected for testing. Cause: Unknown. Effect: The Organization may allocate unallowable costs to the grant. Repeat Finding: No. Recommendation: We recommend that only costs incurred during the period of performance be charged to the grant. For payroll in which periods extend over multiple budget periods, we recommend prorating the amount charged to the grant by days worked within the grant period. Views of Responsible Officials: There is no disagreement with the audit finding.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis. Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management. Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared. Cause: Management oversight. Effect: Unable to determine that required reports were based on accurate, supporting documentation. Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports. Views of Responsible Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-002 – Allowable Cost/Cost Principles – Internal Control Over Compliance –Noncompliance Information on Federal Program: U.S. Department of Health and Human Services ALN Number: 93.243 ALN Name: Substance Abuse and Mental Health Service Projects of Regional and National Significance Grant Award Number: 1H79TI083607-01 Contract Period: 07/01/2022 - 6/30/2023 Criteria: The 2 CFR Part 200 establishes cost principles for determining costs applicable to federal awards. The OMB Compliance Supplement, Part 3 – Compliance Requirements, Allowable Cost/Cost Principles notes that “Direct costs are those costs that can be identified specifically with a particular final cost objective, such as a federal award, or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy.” Further, the Uniform Guidance Section §200.403(g) states that for costs to be allowable under federal awards, they must be adequately documented, and there must be sufficient documentation. Condition: During our testing of personnel costs, we noted that one employee was improperly classified as an hourly employee instead of a salary-based employee which led to the employee being paid $200 more per paycheck for four pay periods. Cause: The overpayment was due to human error caused by the Human Resource clerk. The employee sampled was a salaried employee, however, in the timekeeping system the employee was classified as an hourly employee in error. This led to payroll not being able to review and make adjustments to this employee’s hours (related to any leave taken during the pay period) when payroll ran the timekeeping system report for salary employees and led to the employee being overpaid. Effect or Potential Effect: This resulted to the questioned costs noted above. Questioned Costs: Known questioned costs of $800 in relation to our sample. Unable to determine unknown questioned costs. Context: We tested a sample of 40 items and found one employee exception as noted in the condition. The sampled employee occurred twice in sampled items that were tested during the audit and based on information reviewed, the total overpayment to this employee amounted to $800. This is a condition identified per review of the Organization’s compliance with specified requirements using a statistically valid sample. Recommendation: In order to facilitate accurate reporting and compliance with terms and conditions of federal awards, we recommend management to enhance controls related to payroll processing to ensure that payroll is accurate prior processing and payment to employees. This also assists in ensuring that only allowable costs are charged to the program. Views of Responsible Official and Planned Corrective Action: The Company agrees with the finding identified. The Company’s response to the finding is described in the accompanying management’s corrective action plan.
2023-003 – Allowable Cost/Cost Principles – Internal Control Over Compliance –Noncompliance Information on Federal Program: U.S. Department of Health and Human Services ALN Number: 93.243 ALN Name: Substance Abuse and Mental Health Service Projects of Regional and National Significance Grant Award Number: 1H79TI084507-01 Contract Period: 07/01/2022 - 6/30/2023 Criteria: The 2 CFR Part 200 establishes cost principles for determining costs applicable to federal awards. The OMB Compliance Supplement, Part 3 – Compliance Requirements, Allowable Cost/Cost Principles notes that “Direct costs are those costs that can be identified specifically with a particular final cost objective, such as a federal award, or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy.” Further, the Uniform Guidance Section §200.403(g) states that for costs to be allowable under federal awards, they must be adequately documented, and there must be sufficient documentation. Condition: During our testing of personnel costs, we noted that one employee received a full bi-weekly pay even after termination. This resulted to an overpayment to the employee amounting to $6,923 which was charged to the program. Cause: The overpayment was due to an oversight and payroll missing to update the employee’s status to terminated in the payroll system. Effect or Potential Effect: This resulted to the questioned costs noted above. Questioned Costs: Known questioned costs of $6,923 in relation to our sample. Unable to determine unknown questioned costs. Context: We tested a sample of 40 items and found one exception amounting to $6,923 as noted in the condition. This is a condition identified per review of the Organization’s compliance with specified requirements using a statistically valid sample. Recommendation: In order to facilitate accurate reporting and compliance with terms and conditions of federal awards, we recommend management to enhance controls related to payroll processing to ensure that payroll is accurate prior to processing and payment to employees. Management should also consider automating the process, where possible, to avoid human errors in the process. This also assists in ensuring that only allowable costs are charged to the program. Views of Responsible Official and Planned Corrective Action: The Company agrees with the finding identified. The Company’s response to the finding is described in the accompanying management’s corrective action plan.
Criteria or specific requirement (including statutory, regulatory, or other citation) - Per 2 CFR Subpart E- Cost Principles Part 200.403 (g) states that except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards "(g) Be adequately documented." Per Part 200.413 (a) Direct costs are those costs that can be identified specifically with a particular final cost objective. Condition - The Special Education District prepared, and the cognizant agency approved, a grant budget that included $637,216 of salaries for learning loss, summer enrichment and after school programs (run by member districts). The Special Education District claimed grant expenditures for payments to member districts as salaries. Questioned Costs - Unknown. Context - The Special Education District budgeted and claimed salaries on grant expenditure reports however these expenditures were not salaries incurred directly by the Special Education District, but rather payments to member districts. The grant agreement stipulated that "no subcontracts or sub-grants are allowed without prior written approval of the State Superintendent of Education. If subcontracts or sub-grants are allowed, then all project responsibilities are to be retained by the grantee to ensure compliance with the terms and conditions of the grant. All subcontracts and sub-grants must be documented and must have the prior written approval of the State Superintendent of Education. Approval of subcontracts and sub-grants shall be subject to the same criteria as are applied to the original proposal/application. " Effect - Grant expenditures claimed as salaries on the expenditure reports were payments to member districts which no invoice, representations, or documented by the member districts to the Special Education District as to how the funds were used. Cause - The Special Education District disbursed funds, without documentation, to member districts. Recommendation - We recommend that in the future the Special Education District prepare grant budgets that align with the expected grant expenditures and that expenditures be adequately documented as to the use of funds. Management's response - Management does not agree with this finding. Management reached out to the cognizant agency which provided the following response - "The ESSER III Cooperative grant was state set-aside funds that were originally awarded to ISBE. ISBE determined that to meet the stipulations of Learning Loss-Summer Enrichment-After School Program reservations, the most efficient way to reach the maximum number of students would be through the cooperatives providing for their member districts. Henry-Stark County Special Education District met those requirements and fulfilled their financial obligations by providing evidence-based activities through their member districts"
Criteria or specific requirement (including statutory, regulatory, or other citation) - Per 2 CFR Subpart E- Cost Principles Part 200.403 (g) states that except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards "(g) Be adequately documented." Per Part 200.413 (a) Direct costs are those costs that can be identified specifically with a particular final cost objective. Condition - The Special Education District prepared, and the cognizant agency approved, a grant budget that included $637,216 of salaries for learning loss, summer enrichment and after school programs (run by member districts). The Special Education District claimed grant expenditures for payments to member districts as salaries. Questioned Costs - Unknown. Context - The Special Education District budgeted and claimed salaries on grant expenditure reports however these expenditures were not salaries incurred directly by the Special Education District, but rather payments to member districts. The grant agreement stipulated that "no subcontracts or sub-grants are allowed without prior written approval of the State Superintendent of Education. If subcontracts or sub-grants are allowed, then all project responsibilities are to be retained by the grantee to ensure compliance with the terms and conditions of the grant. All subcontracts and sub-grants must be documented and must have the prior written approval of the State Superintendent of Education. Approval of subcontracts and sub-grants shall be subject to the same criteria as are applied to the original proposal/application. " Effect - Grant expenditures claimed as salaries on the expenditure reports were payments to member districts which no invoice, representations, or documented by the member districts to the Special Education District as to how the funds were used. Cause - The Special Education District disbursed funds, without documentation, to member districts. Recommendation - We recommend that in the future the Special Education District prepare grant budgets that align with the expected grant expenditures and that expenditures be adequately documented as to the use of funds. Management's response - Management does not agree with this finding. Management reached out to the cognizant agency which provided the following response - "The ESSER III Cooperative grant was state set-aside funds that were originally awarded to ISBE. ISBE determined that to meet the stipulations of Learning Loss-Summer Enrichment-After School Program reservations, the most efficient way to reach the maximum number of students would be through the cooperatives providing for their member districts. Henry-Stark County Special Education District met those requirements and fulfilled their financial obligations by providing evidence-based activities through their member districts"