2023-062 The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with financial reporting requirements for the Child Care and Development Fund Cluster. Assistance Listing Number and Title: 93.575 Child Care and Development Block Grant 93.575 COVID-19 Child Care and Development Block Grant 93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund Federal Grantor Name: U.S. Department of Health and Human Service Federal Award/Contract Number: 2103WACCDF; 2103WACCDD; 2203WACCDF; 2203WACCDD; 2303WACCDF; 2303WACCDD; 2003WACCC3; 2103WACDC6; 2103WACSC6; 2103WACCC5 Pass-through Entity Name: None Pass-through Award/Contract Number: None Applicable Compliance Component: Reporting Known Questioned Cost Amount: None Prior Year Audit Finding: Yes, Finding 2022-044 Background The Department of Children, Youth, and Families administers the federal Child Care and Development Fund (CCDF) grants to help eligible working families pay for child care and fund improvements to child care quality. In fiscal year 2023, the Department spent about $547.2 million in federal funding. The Department is required to submit a quarterly ACF-696 financial report for each open grant. These reports contain information on expenditures for three CCDF funding sources: the Mandatory Fund, the Matching Fund, and the Discretionary Fund. The Department uses CCDF expenditures recorded in the state’s accounting system to compile and support the ACF-696 report. The U.S. Department of Health and Human Services (HHS), which oversees the CCDF program at the federal level, requires recipients to have accounting procedures that are sufficient for tracing grants to a level of expenditure adequate to show that they have been used in accordance with program requirements. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. In prior audits, we reported the Department did not have adequate internal controls over financial reporting requirements for the CCDF program. The prior finding numbers were 2022-044 and 2021-038. Description of Condition The Department did not have adequate internal controls over and did not comply with financial reporting requirements for the CCDF program. The Department’s accounting records must provide and support the financial information reported on ACF-696 reports. During the audit period, the Department’s grant management practice was to process expenditure transfers at the fund level without identifying which expenditures it transferred. Therefore, we could not rely on the data supporting the Department’s reported ACF-696 expenditures and could not test whether the reports were accurate and complete. This condition is also referenced in audit finding 2023-058. We consider these internal control deficiencies to be a material weakness, which led to material noncompliance. Cause of Condition The Department is required to maintain sufficient documentation for each payment it makes using federal dollars. The Department’s accounting practices prevent it from meeting this requirement. In fiscal year 2021, the Department informed our Office that it had implemented what management referred to as fund-level accounting. This consisted of making significant accounting adjustments between funding sources in its general ledger without identifying the underlying transactions in the payment system that supported them. This affected all populations of childcare expenditures for every month of the fiscal year. HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant. Effect of Condition By not complying with requirements in federal law to maintain adequate supporting documentation for expenditures, the Department created a condition that made it impossible for our Office to audit the CCDF program expenditures reported on the ACF-696 financial report. Recommendations We recommend the Department design and implement internal controls to ensure the ACF-696 report is supported with transaction-level data that is sufficient to comply with federal law and state rules. Department’s Response The Department has managed the CCDF program since 2019, prior to that it was managed by the Department of Social and Health Services and the Department of Early Learning. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF grants to eligible clients and allowable activities in compliance with 45 CFR 98.67. This process consists of making grant level adjustments between allowable grant sources to properly spend grant dollars within the allowable period of performance and ensure level of effort and matching requirements. The Department’s grant adjustments were processed based on eligible clients and allowable activities and did not include child-level data as required by SAO. The Department held an informal meeting on February 23, 2022, with HHS representative, the State Auditor’s Office and the Office of Financial Management. The intent was to obtain the grantor’s perspective in whether proper grant accounting required the use of child-level data. HHS stated they would not offer an opinion until they received the completed finding from the state. However, the Cause of Condition of finding 2021-033 stated, “HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant.” The Department does not agree with SAO’s interpretation of the meeting outcome. In the area of CCDF eligibility, for state fiscal year 2021, the SAO also issued finding 2021-035, with questioned cost of $32 and in state fiscal year 2022, finding 2022-008 (temporary number) with no questioned costs. There were no other findings or exit items in the area of eligibility determination or the cost allocation of funds. Given that eligibility or cost allocation is not an area of concern and transfers were processed between CCDF source of funds with the same eligibility requirements, the Department is confident CCDF funding was spent appropriately within federal regulations. The Department received a management decision letter dated October 3, 2023, from HHS for finding 2021-033 (2020-038) which states: “the ACF noted that the auditor raised concern about the Department’s accounting procedures and efforts made to trace expenditures at the transaction-level. As the basis for the finding, the auditor used CFRs (200.53, 200.303, 200.403, 200.410) that do not apply to CCDF. Federal regulations allow Lead Agencies to expend and account for CCDF funds in accordance with their own procedures.” In addition, ACF did not sustain the disallowance of questioned costs and stated: “Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” The management decision letter also conveyed the following determination by HHS for finding 2021-035, 2020-039 on eligibility compliance: “The ACF believes the corrective actions taken or planned, as stated above, should prevent recurrence of this finding in the future. In addition, we recognize the continuous progression of the State’s actions to fully resolve this finding as the number of error cases and the number of questioned costs have both significantly declined over the last 3 years. Therefore, the ACF will not pursue the questioned costs of $32 since the state has taken corrective actions that appear to have resulted in an amount of questioned costs that are immaterial.” The ACF recommended, “that the Department work with the auditors to determine an appropriate methodology that can be tested to ensure childcare payments comply with Federal regulations.” The Department met with ACF and SAO on November 8, 2023, to discuss the ACF decision at which time ACF upheld the above statements that the finding was not substantiated. The Department is committed to collaborating with SAO to determine an appropriate methodology that identifies a sampling unit that can be used to accurately test compliance. The SAO maintained that the program is not auditable without child-level data. The Department does not currently have the staff and resources to develop and maintain the business process redesign, as well as the information technology initiatives necessary to meet the level of assurance as identified by SAO. In response to the auditor’s recommendations, the Department has submitted a budget request for the 2024 supplemental budget. If the request is funded, it would allow adjustments to include child-level data. Auditor’s Remarks The level of documentation needed to support grant expenditures is not established by our Office, but in title 45 of the U.S. Code of Federal Regulations and the state’s grant award. During the February 2022 meeting with HHS that the Department referenced in its response, the grantor stated the specific federal law the Department’s accounting procedures were noncompliant with was 45 CFR 98.67. We agree with the HHS management decision that our references to 2 CFR 200.53, 200.303, 200.403 and 200.410 in the prior finding were not correct. However, HHS adopted these same requirements in 45 CFR 75.2, 75.303, 75.403 and 75.410, respectfully. These requirements were all in place during the audit period. The proper references are included in this finding. In its response, the Department references previous findings related to the eligibility compliance requirement as a basis for asserting federal funds were spent properly. The requirements to determine whether a client is eligible to receive subsidized child care are different than the requirements to ensure the payments for those services are allowable, fall within each award’s period of performance and adequately supported. Without adequate transactional level payment data, our Office is unable to perform tests to verify the Department met these requirements. In addition, we also are unable to verify whether the Department complied with matching, level of effort and earmarking requirements, or that required financial information reported to the federal government was accurate. These matters are referenced in separate findings in our report. We disagree with the Department’s description of the meeting held with HHS program staff on November 8, 2023. The Department states HHS “upheld the above statements that the finding was not substantiated.” This is not accurate. During this meeting, HHS representatives conveyed the same message that they did in the management decision issued October 3, 2023. The finding was partially substantiated because the questioned costs identified in the audit would not be disallowed. The management decision states: “The ACF partially sustains the finding and recommendation. The ACF agrees with the auditor that the Department should strengthen internal controls to ensure payments to child care providers are allowable and properly supported.” “The ACF does not sustain a disallowance for the questioned costs in the amount of $271,353,409 representing the entire amount of the CCDF grant award. Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” We are not aware of what procedures ACF performed to conclude expenditures reported by the Department for fiscal year 2022 were spent only for allowable activities, were for allowable costs and met federal cost principles. We questioned all expenditures because, in our judgment, they were unauditable. Lastly, when the Washington State Legislature approved the Department’s 2023-25 biennial budget, it specified: “Funding in this subsection must be expended with internal controls that provide child-level detail for all transactions.” We reaffirm our finding and hope additional resources from the Legislature, to get down to child-level detail for all transactions, will resolve the auditing problems existing at the Department. We will review the status of the Department’s corrective action during our next audit. Applicable Laws and Regulations 45 U.S. Code of Federal Regulations (CFR) Part 75, section 303, Internal Controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 45 CFR Part 75, section 516, Audit findings, establishes reporting requirements for audit findings. Title 45 CFR, Section 98.67 – Fiscal requirements, states: (a) Lead Agencies shall expend and account for CCDF funds in accordance with their own laws and procedures for expending and accounting for their own funds. (b) Unless otherwise specified in this part, contracts that entail the expenditure of CCDF funds shall comply with the laws and procedures generally applicable to expenditures by the contracting agency of its own funds. (c) Fiscal control and accounting procedures shall be sufficient to permit: (1) Preparation of reports required by the Secretary under this subpart and under subpart H; and (2) The tracking of funds to a level of expenditure adequate to establish that such funds have not been used in violation of the provisions of this part. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2023-058 The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with requirements to ensure payments to child care providers for the Child Care and Development Fund Cluster programs were allowable and properly supported. Assistance Listing Number and Title: 93.575 Child Care and Development Block Grant 93.575 COVID-19 Child Care and Development Block Grant 93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund Federal Grantor Name: U.S. Department of Health and Human Services Federal Award/Contract Number: 2103WACCDF; 2103WACCDD; 2203WACCDF; 2203WACCDD; 2303WACCDF; 2303WACCDD; 2003WACCC3; 2103WACDC6; 2103WACSC6; 2103WACCC5 Pass-through Entity Name: None Pass-through Award/Contract Number: None Applicable Compliance Component: Activities Allowed or Unallowed Allowable Costs/Cost Principles Known Questioned Cost Amount: $356,042,172 Prior Year Audit Finding: Yes, Finding 2022-041 Background The Department of Children, Youth, and Families administers the federal Child Care and Development Fund (CCDF) grants to help eligible working families pay for child care and fund improvements to child care quality. In fiscal year 2023, the Department spent about $547.2 million in federal funding. The Department is responsible for establishing policies to ensure payments to providers for child care services are allowable. In fiscal year 2023, the Department spent more than $356 million on monthly child care subsidy payments to child care providers. There are three child care provider types: licensed centers, licensed family homes, and licensed exempt providers referred to as Family, Friends and Neighbor providers. The Department uses the Social Service Payment System (SSPS) to process the payments it makes to child care providers. The system allocates payments to various funding sources, based on the eligibility of the client. These funding sources include multiple federal programs, multiple CCDF federal grant awards, and state funding. The Department uploads the SSPS payment data into the state’s accounting system at a summary level based on the various funding sources. There is always a need to transfer the funding sources for some payments throughout the year to manage federal and state funds properly. In prior audit periods up until fiscal year 2021, the Department prepared supporting documentation for transfers that included details of what payments it was transferring. The purpose of documenting this detail was to maintain proper support for federal expenditures. The Department of Health and Human Services (HHS), which oversees the CCDF program at the federal level, requires recipients have accounting procedures that are sufficient for tracing grants to a level of expenditure adequate to show that they have been used in accordance with program requirements. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. In prior audits, we reported the Department did not have adequate internal controls over and did not comply with requirements to ensure payments to child care providers were allowable and properly supported. We have reported this condition since 2005. The most recent audit finding numbers were 2022-041, 2021-033, 2020-038, 2019-035, 2018–034, 2017-024, 2016-021, 2015-023, 2014-023, 2013-016, 12-28, 11-23, 10-31, 9-12 and 8–13. Description of Condition The Department did not have adequate internal controls over and did not comply with requirements to ensure payments to child care providers for the CCDF programs were allowable and properly supported. In fiscal year 2021, management informed us that the Department changed its grant management practices to process expenditure transfers at the grant level. This new process made the original expenditure coding in SSPS inaccurate and unreliable for testing. As a result, we could not trace the federal funds to a level of expenditure adequate to establish whether the Department spent CCDF funds in accordance with federal and state regulations. Further, this meant we could not test the Department’s payments to child care providers for compliance with activities allowed and cost principles. By processing these adjustments at the fund level, the Department invalidated the transaction-level documentation of the original child care expenditure in SSPS and did not identify the new allocation at the payment level. Additionally, the Department transferred some of these child care expenditures more than once at the fund level, making the underlying data increasingly unreliable with each transfer. We consider these internal control deficiencies to be a material weakness, which led to material noncompliance. Cause of Condition The Department is required to maintain sufficient documentation for each payment it makes with federal dollars. The Department’s accounting practices prevent it from meeting this requirement. The Department implemented what management referred to as fund-level accounting. This consisted of making significant accounting adjustments between funding sources in its general ledger without identifying the underlying transactions in the payment system that supported the adjustments. This affected all populations of child care expenditures for every month of the fiscal year. HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant. Effect of Condition By not complying with requirements in federal law to maintain adequate supporting documentation for expenditures, the Department created a condition that made it impossible for our Office to audit the federal dollars it used for payments to child care providers. Because we could not test transaction-level detail, we also could not determine whether the issues we identified in prior audits had improved or worsened, including the Department’s lack of adequate internal controls and significant rate of noncompliance for payments to child care providers. The total amount of known child care payments with federal CCDF funds in the audit period was $356,042,172. The Department also partially funded these payments with an additional $48,941,302 in state dollars. Because the Department did not comply with HHS requirements to allow for the tracing of grant expenditures to a payment level, we are questioning all $356,042,172 in federal program costs the Department incurred during the audit period. The payments the Department partially paid with state funds are not included in the federal questioned costs. We question costs when we find an agency has not complied with grant regulations or when it does not have adequate documentation to support its expenditures. Recommendations We recommend the Department: • Design and implement internal controls to ensure transaction-level data is sufficient to comply with federal law and state rules • Consult with the grantor to discuss whether the questioned costs identified in the audit should be repaid Department’s Response The Department has managed the CCDF program since 2019, prior to that it was managed by the Department of Social and Health Services and the Department of Early Learning. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF grants to eligible clients and allowable activities in compliance with 45 CFR 98.67. This process consists of making grant level adjustments between allowable grant sources to properly spend grant dollars within the allowable period of performance and ensure level of effort and matching requirements. The Department’s grant adjustments were processed based on eligible clients and allowable activities and did not include child-level data as required by SAO. The Department held an informal meeting on February 23, 2022, with HHS representative, the State Auditor’s Office and the Office of Financial Management. The intent was to obtain the grantor’s perspective in whether proper grant accounting required the use of child-level data. HHS stated they would not offer an opinion until they received the completed finding from the state. However, the Cause of Condition of finding 2021-033 stated, “HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant.” The Department does not agree with SAO’s interpretation of the meeting outcome. In the area of CCDF eligibility, for state fiscal year 2021, the SAO also issued finding 2021-035, with questioned cost of $32 and in state fiscal year 2022, finding 2022-008 (temporary number) with no questioned costs. There were no other findings or exit items in the area of eligibility determination or the cost allocation of funds. Given that eligibility or cost allocation is not an area of concern and transfers were processed between CCDF source of funds with the same eligibility requirements, the Department is confident CCDF funding was spent appropriately within federal regulations. The Department received a management decision letter dated October 3, 2023, from HHS for finding 2021-033 (2020-038) which states: “the ACF noted that the auditor raised concern about the Department’s accounting procedures and efforts made to trace expenditures at the transaction-level. As the basis for the finding, the auditor used CFRs (200.53, 200.303, 200.403, 200.410) that do not apply to CCDF. Federal regulations allow Lead Agencies to expend and account for CCDF funds in accordance with their own procedures.” In addition, ACF did not sustain the disallowance of questioned costs and stated: “Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” The management decision letter also conveyed the following determination by HHS for finding 2021-035, 2020-039 on eligibility compliance: “The ACF believes the corrective actions taken or planned, as stated above, should prevent recurrence of this finding in the future. In addition, we recognize the continuous progression of the State’s actions to fully resolve this finding as the number of error cases and the amount of questioned costs have both significantly declined over the last 3 years. Therefore, the ACF will not pursue the questioned costs of $32 since the state has taken corrective actions that appear to have resulted in an amount of questioned costs that are immaterial.” The ACF recommended, “that the Department work with the auditors to determine an appropriate methodology that can be tested to ensure child care payments comply with Federal regulations.” The Department met with ACF and SAO on November 8, 2023, to discuss the ACF decision at which time ACF upheld the above statements that the finding was not substantiated. The Department is committed to collaborating with SAO to determine an appropriate methodology that identifies a sampling unit that can be used to accurately test compliance. The SAO maintained that the program is not auditable without child-level data. The Department does not currently have the staff and resources to develop and maintain the business process redesign, as well as the information technology initiatives necessary to meet the level of assurance as identified by SAO. In response to the auditor’s recommendations, the Department has submitted a budget request for the 2024 supplemental budget. If the request is funded, it would allow adjustments to include child-level data. Auditor’s Remarks The level of documentation needed to support grant expenditures is not established by our Office, but in title 45 of the U.S. Code of Federal Regulations and the state’s grant award. During the February 2022 meeting with HHS that the Department referenced in its response, the grantor stated the specific federal law the Department’s accounting procedures were noncompliant with was 45 CFR 98.67. We agree with the HHS management decision that our references to 2 CFR 200.53, 200.303, 200.403 and 200.410 in the prior finding were not correct. However, HHS adopted these same requirements in 45 CFR 75.2, 75.303, 75.403 and 75.410, respectfully. These requirements were all in place during the audit period. The proper references are included in this finding. In its response, the Department references previous findings related to the eligibility compliance requirement as a basis for asserting federal funds were spent properly. The requirements to determine whether a client is eligible to receive subsidized child care are different than the requirements to ensure the payments for those services are allowable, fall within each award’s period of performance and adequately supported. Without adequate transactional level payment data, our Office is unable to perform tests to verify the Department met these requirements. In addition, we also are unable to verify whether the Department complied with matching, level of effort and earmarking requirements, or that required financial information reported to the federal government was accurate. These matters are referenced in separate findings in our report. We disagree with the Department’s description of the meeting held with HHS program staff on November 8, 2023. The Department states HHS “upheld the above statements that the finding was not substantiated.” This is not accurate. During this meeting, HHS representatives conveyed the same message that they did in the management decision issued October 3, 2023. The finding was partially substantiated because the questioned costs identified in the audit would not be disallowed. The management decision states: “The ACF partially sustains the finding and recommendation. The ACF agrees with the auditor that the Department should strengthen internal controls to ensure payments to child care providers are allowable and properly supported.” “The ACF does not sustain a disallowance for the questioned costs in the amount of $271,353,409 representing the entire amount of the CCDF grant award. Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” We are not aware of what procedures ACF performed to conclude expenditures reported by the Department for fiscal year 2022 were spent only for allowable activities, were for allowable costs and met federal cost principles. We questioned all expenditures because, in our judgment, they were unauditable. Lastly, when the Washington State Legislature approved the Department’s 2023-25 biennial budget, it specified: “Funding in this subsection must be expended with internal controls that provide child-level detail for all transactions.” We reaffirm our finding and hope additional resources from the Legislature, to get down to child-level detail for all transactions, will resolve the auditing problems existing at the Department. We will review the status of the Department’s corrective action during our next audit. Applicable Laws and Regulations 45 U.S. Code of Federal Regulations (CFR) Part 75, section 2, Definitions, includes the definition of improper payment. 45 CFR Part 75, section 303, Internal Controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. 45 CFR Part 75, section 403, Factors Affecting Allowability of Costs. 45 CFR Part 75, section 410, Collection of Unallowable Costs 45 CFR Part 75, section 516, Audit findings, establishes reporting requirements for audit findings. Title 45 CFR, Section 98.67 – Fiscal requirements, states: (a) Lead Agencies shall expend and account for CCDF funds in accordance with their own laws and procedures for expending and accounting for their own funds. (b) Unless otherwise specified in this part, contracts that entail the expenditure of CCDF funds shall comply with the laws and procedures generally applicable to expenditures by the contracting agency of its own funds. (c) Fiscal control and accounting procedures shall be sufficient to permit: (1) Preparation of reports required by the Secretary under this subpart and under subpart H; and (2) The tracking of funds to a level of expenditure adequate to establish that such funds have not been used in violation of the provisions of this part. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2023-060 The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with matching, level of effort, and earmarking requirements for the Child Care and Development Fund Cluster. Assistance Listing Number and Title: 93.575 Child Care and Development Block Grant 93.575 COVID-19 Child Care and Development Block Grant 93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund Federal Grantor Name: U.S. Department of Health and Human Services Federal Award/Contract Number: 2103WACCDF; 2103WACCDD; 2203WACCDF; 2203WACCDD; 2303WACCDF; 2303WACCDD; 2003WACCC3; 2103WACDC6; 2103WACSC6; 2103WACCC5 Pass-through Entity Name: None Pass-through Award/Contract Number: None Applicable Compliance Component: Matching, Level of Effort, Earmarking Known Questioned Cost Amount: None Prior Year Audit Finding: Yes, Finding 2022-042 Background The Department of Children, Youth, and Families administers the federal Child Care and Development Fund (CCDF) grants to help eligible working families pay for child care and fund improvements to child care quality. In fiscal year 2023, the Department spent about $547.2 million in federal funding. The CCDF consists of three distinct funding sources: Discretionary Fund, Mandatory Fund, and Matching Fund. Additionally, under the Temporary Assistance for Needy Families (TANF) program, the Department may transfer TANF funds to the CCDF, which are then treated as Discretionary Funds. The Department is instructed how to spend this federal money. For the Department to receive its allotted share of the Matching Fund, it must meet the Maintenance of Effort (MOE) requirement and match the federal Matching Fund claimed with state expenditures at the Federal Medical Assistance Percentage rate for the applicable fiscal year. The Department must also meet earmarking requirements for expenditures for administrative and quality activities. The U.S. Department of Health and Human Services (HHS), which oversees the CCDF program at the federal level, requires recipients have accounting procedures that are sufficient for tracing grants to a level of expenditure adequate to show that they have been used in accordance with program requirements. Department staff run monthly and quarterly expenditure reports from the accounting system to track requirements over matching, level of effort, and earmarking for each open grant award. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. In prior audits, we reported the Department did not have adequate internal controls over matching, level of effort, and earmarking requirements for the CCDF Cluster programs. The prior audit finding numbers were 2022-042, 2021-036, and 2020-040. Description of Condition The Department did not have adequate internal controls over and did not comply with matching, level of effort, and earmarking requirements for the CCDF programs. The Department’s accounting records should be used to verify it has met matching, level of effort, and earmarking requirements. In fiscal year 2021, management informed us that the Department changed its grant management practices to process expenditure transfers at the grant level. This new process made the original expenditure coding in the payment system inaccurate and unreliable for testing. Without identifying which expenditures it transferred, the Department’s monitoring is insufficient for properly managing matching, level of effort, and earmarking requirements. Our Office could not rely on the data supporting the Department’s expenditures or verify that the accounting records were accurate. As a result, we could not trace the federal funds to a level of expenditure adequate to establish whether the Department spent CCDF funds in accordance with federal and state regulations. Further, this meant we could not test the Department’s payments for compliance with matching, level of effort, and earmarking requirements. By processing these adjustments at the fund level, the Department invalidated the transaction-level documentation of the original child care expenditure in the payment system, and did not identify the new allocation at the payment level. Additionally, the Department transferred some of these child care expenditures more than once at the fund level, making the underlying data increasingly unreliable with each transfer. This condition is also referenced in audit finding 2023-058. We consider these internal control deficiencies to be a material weakness, which led to material noncompliance. Cause of Condition The Department is required to maintain sufficient documentation for each payment it makes with federal dollars. The Department’s accounting practices prevent it from meeting this requirement. In fiscal year 2021, the Department informed our Office that it had implemented what management referred to as fund-level accounting. This consisted of making significant accounting adjustments between funding sources in its general ledger without identifying the underlying transactions in the payment system that supported the adjustments. This affected all populations of child care expenditures for every month of the fiscal year. HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant. Effect of Condition By not complying with requirements in federal law to maintain adequate supporting documentation for expenditures the Department created a condition that made it impossible for our Office to determine if it had met matching, level of effort, and earmarking requirements. Recommendations We recommend the Department: • Design and implement internal controls to ensure transaction-level data is sufficient to comply with federal law and state rules • Develop effective ongoing monitoring procedures Department’s Response The Department has managed the CCDF program since 2019, prior to that it was managed by the Department of Social and Health Services and the Department of Early Learning. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF grants to eligible clients and allowable activities in compliance with 45 CFR 98.67. This process consists of making grant level adjustments between allowable grant sources to properly spend grant dollars within the allowable period of performance and ensure level of effort and matching requirements. The Department’s grant adjustments were processed based on eligible clients and allowable activities and did not include child-level data as required by SAO. The Department held an informal meeting on February 23, 2022, with HHS representative, the State Auditor’s Office and the Office of Financial Management. The intent was to obtain the grantor’s perspective in whether proper grant accounting required the use of child-level data. HHS stated they would not offer an opinion until they received the completed finding from the state. However, the Cause of Condition of finding 2021-033 stated, “HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant.” The Department does not agree with SAO’s interpretation of the meeting outcome. In the area of CCDF eligibility, for state fiscal year 2021, the SAO also issued finding 2021-035, with questioned cost of $32 and in state fiscal year 2022, finding 2022-008 (temporary number) with no questioned costs. There were no other findings or exit items in the area of eligibility determination or the cost allocation of funds. Given that eligibility or cost allocation is not an area of concern and transfers were processed between CCDF source of funds with the same eligibility requirements, the Department is confident CCDF funding was spent appropriately within federal regulations. The Department received a management decision letter dated October 3, 2023, from HHS for finding 2021-033 (2020-038) which states: “the ACF noted that the auditor raised concern about the Department’s accounting procedures and efforts made to trace expenditures at the transaction-level. As the basis for the finding, the auditor used CFRs (200.53, 200.303, 200.403, 200.410) that do not apply to CCDF. Federal regulations allow Lead Agencies to expend and account for CCDF funds in accordance with their own procedures.” In addition, ACF did not sustain the disallowance of questioned costs and stated: “Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” The management decision letter also conveyed the following determination by HHS for finding 2021-035, 2020-039 on eligibility compliance: “The ACF believes the corrective actions taken or planned, as stated above, should prevent recurrence of this finding in the future. In addition, we recognize the continuous progression of the State’s actions to fully resolve this finding as the number of error cases and the amount of questioned costs have both significantly declined over the last 3 years. Therefore, the ACF will not pursue the questioned costs of $32 since the state has taken corrective actions that appear to have resulted in an amount of questioned costs that are immaterial.” The ACF recommended, “that the Department work with the auditors to determine an appropriate methodology that can be tested to ensure child care payments comply with Federal regulations.” The Department met with ACF and SAO on November 8, 2023, to discuss the ACF decision at which time ACF upheld the above statements that the finding was not substantiated. The Department is committed to collaborating with SAO to determine an appropriate methodology that identifies a sampling unit that can be used to accurately test compliance. The SAO maintained that the program is not auditable without child-level data. The Department does not currently have the staff and resources to develop and maintain the business process redesign, as well as the information technology initiatives necessary to meet the level of assurance as identified by SAO. In response to the auditor’s recommendations, the Department has submitted a budget request for the 2024 supplemental budget. If the request is funded, it would allow adjustments to include child-level data. Auditor’s Remarks The level of documentation needed to support grant expenditures is not established by our Office, but in title 45 of the U.S. Code of Federal Regulations and the state’s grant award. During the February 2022 meeting with HHS that the Department referenced in its response, the grantor stated the specific federal law the Department’s accounting procedures were noncompliant with was 45 CFR 98.67. We agree with the HHS management decision that our references to 2 CFR 200.53, 200.303, 200.403 and 200.410 in the prior finding were not correct. However, HHS adopted these same requirements in 45 CFR 75.2, 75.303, 75.403 and 75.410, respectfully. These requirements were all in place during the audit period. The proper references are included in this finding. In its response, the Department references previous findings related to the eligibility compliance requirement as a basis for asserting federal funds were spent properly. The requirements to determine whether a client is eligible to receive subsidized child care are different than the requirements to ensure the payments for those services are allowable, fall within each award’s period of performance and adequately supported. Without adequate transactional level payment data, our Office is unable to perform tests to verify the Department met these requirements. In addition, we also are unable to verify whether the Department complied with matching, level of effort and earmarking requirements, or that required financial information reported to the federal government was accurate. These matters are referenced in separate findings in our report. We disagree with the Department’s description of the meeting held with HHS program staff on November 8, 2023. The Department states HHS “upheld the above statements that the finding was not substantiated.” This is not accurate. During this meeting, HHS representatives conveyed the same message that they did in the management decision issued October 3, 2023. The finding was partially substantiated because the questioned costs identified in the audit would not be disallowed. The management decision states: “The ACF partially sustains the finding and recommendation. The ACF agrees with the auditor that the Department should strengthen internal controls to ensure payments to child care providers are allowable and properly supported.” “The ACF does not sustain a disallowance for the questioned costs in the amount of $271,353,409 representing the entire amount of the CCDF grant award. Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” We are not aware of what procedures ACF performed to conclude expenditures reported by the Department for fiscal year 2022 were spent only for allowable activities, were for allowable costs and met federal cost principles. We questioned all expenditures because, in our judgment, they were unauditable. Lastly, when the Washington State Legislature approved the Department’s 2023-25 biennial budget, it specified: “Funding in this subsection must be expended with internal controls that provide child-level detail for all transactions.” We reaffirm our finding and hope additional resources from the Legislature, to get down to child-level detail for all transactions, will resolve the auditing problems existing at the Department. We will review the status of the Department’s corrective action during our next audit. Applicable Laws and Regulations 45 U.S. Code of Federal Regulations (CFR) Part 75, section 303, Internal Controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 45 CFR Part 75, section 516, Audit findings, establishes reporting requirements for audit findings. Title 45 CFR, Section 98.67 – Fiscal requirements, states: (a) Lead Agencies shall expend and account for CCDF funds in accordance with their own laws and procedures for expending and accounting for their own funds. (b) Unless otherwise specified in this part, contracts that entail the expenditure of CCDF funds shall comply with the laws and procedures generally applicable to expenditures by the contracting agency of its own funds. (c) Fiscal control and accounting procedures shall be sufficient to permit: (1) Preparation of reports required by the Secretary under this subpart and under subpart H; and (2) The tracking of funds to a level of expenditure adequate to establish that such funds have not been used in violation of the provisions of this part. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2023-061 The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with period of performance requirements for the Child Care and Development Fund Cluster. Assistance Listing Number and Title: 93.575 Child Care and Development Block Grant 93.575 COVID-19 Child Care and Development Block Grant 93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund Federal Grantor Name: U.S. Department of Health and Human Services Federal Award/Contract Number: 2103WACCDF; 2103WACCDD; 2203WACCDF; 2203WACCDD; 2303WACCDF; 2303WACCDD; 2003WACCC3; 2103WACDC6; 2103WACSC6; 2103WACCC5 Pass-through Entity Name: None Pass-through Award/Contract Number: None Applicable Compliance Component: Period of Performance Known Questioned Cost Amount: None Prior Year Audit Finding: Yes, Finding 2022-043 Background The Department of Children, Youth, and Families administers the federal Child Care and Development Fund (CCDF) grants to help eligible working families pay for child care and fund improvements to child care quality. In fiscal year 2023, the Department spent about $547.2 million in federal funding. Each federal grant specifies a performance period during which recipients must obligate and liquidate program costs. These periods typically align with the federal fiscal year of October 1 through September 30. Payments for costs charged before a grant’s beginning date or after the ending date are not allowed without the grantor’s prior approval. The CCDF consists of three distinct funding sources: Discretionary Fund, Mandatory Fund, and Matching Fund. Each of these funds has specific period of performance requirements established in federal regulation (45 CFR § 98.60(d)): • Discretionary Funds must be obligated by the end of the succeeding fiscal year after award and expended by the end of the third fiscal year after award. • Mandatory Funds must be obligated by the end of the fiscal year in which they are awarded if the state also requests Matching Funds. If no Matching Funds are requested for the fiscal year, then the Mandatory Funds are available until liquidated. • Matching Funds must be obligated by the end of the fiscal year in which they are awarded and liquidated by the end of the succeeding fiscal year after award. During the audit period, the Department also received supplemental funds under the Coronavirus Aid, Relief, and Economic Security (CARES) and the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Acts. These funds are treated as Discretionary Funds, however, they have their own specific obligation and liquidation timeframes. The U.S. Department of Health and Human Services (HHS), which oversees the CCDF at the federal level, requires recipients to have accounting procedures that are sufficient for tracing grants to a level of expenditure adequate to show that they have been used in accordance with program requirements. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. In prior audits, we reported the Department did not have adequate internal controls over period of performance requirements for the CCDF program. The prior finding numbers were 2022-043, 2021-037, and 2020-041. Description of Condition The Department did not have adequate internal controls over and did not comply with period of performance requirements for the CCDF program. Our Office uses the Department’s accounting records to verify it has met the period of performance requirements. In fiscal year 2021, management informed us that the Department changed its grant management practices to process expenditure transfers at the grant level. This new process made the original expenditures coded in the payment system inaccurate and unreliable for audit testing. As a result, we could not trace the federal funds to a level of expenditure adequate to establish whether the Department spent CCDF funds in accordance with federal and state regulations. Further, this meant we could not test the Department’s payments for compliance with period of performance requirements. This condition is also referenced in audit finding 2023-058. We consider these internal control deficiencies to be a material weakness, which led to material noncompliance. Cause of Condition The Department is required to maintain sufficient documentation for each payment it makes with federal dollars. The Department’s accounting practices prevent it from meeting this requirement. The Department implemented what management referred to as fund-level accounting. This consisted of making significant accounting adjustments between funding sources in its general ledger without identifying the underlying transactions in the payment system that supported the adjustments. This affected all populations of child care expenditures for every month of the fiscal year. HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant. Effect of Condition By not complying with requirements in federal law to maintain adequate supporting documentation for expenditures, the Department created a condition that made it impossible for our Office to determine if it materially met the period of performance requirements. Furthermore, without adequate internal controls in place, the Department is at a higher risk of making improper payments with grant funds. Recommendations We recommend the Department: • Design and implement internal controls to ensure transaction-level data is sufficient to comply with federal law and state rules • Develop written policies and procedures over federal period of performance requirements Department’s Response The Department has managed the CCDF program since 2019, prior to that it was managed by the Department of Social and Health Services and the Department of Early Learning. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF grants to eligible clients and allowable activities in compliance with 45 CFR 98.67. This process consists of making grant level adjustments between allowable grant sources to properly spend grant dollars within the allowable period of performance and ensure level of effort and matching requirements. The Department’s grant adjustments were processed based on eligible clients and allowable activities and did not include child-level data as required by SAO. The Department held an informal meeting on February 23, 2022, with HHS representative, the State Auditor’s Office and the Office of Financial Management. The intent was to obtain the grantor’s perspective in whether proper grant accounting required the use of child-level data. HHS stated they would not offer an opinion until they received the completed finding from the state. However, the Cause of Condition of finding 2021-033 stated, “HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant.” The Department does not agree with SAO’s interpretation of the meeting outcome. In the area of CCDF eligibility, for state fiscal year 2021, the SAO also issued finding 2021-035, with questioned cost of $32 and in state fiscal year 2022, finding 2022-008 (temporary number) with no questioned costs. There were no other findings or exit items in the area of eligibility determination or the cost allocation of funds. Given that eligibility or cost allocation is not an area of concern and transfers were processed between CCDF source of funds with the same eligibility requirements, the Department is confident CCDF funding was spent appropriately within federal regulations. The Department received a management decision letter dated October 3, 2023, from HHS for finding 2021-033 (2020-038) which states: “the ACF noted that the auditor raised concern about the Department’s accounting procedures and efforts made to trace expenditures at the transaction-level. As the basis for the finding, the auditor used CFRs (200.53, 200.303, 200.403, 200.410) that do not apply to CCDF. Federal regulations allow Lead Agencies to expend and account for CCDF funds in accordance with their own procedures.” In addition, ACF did not sustain the disallowance of questioned costs and stated: “Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” The management decision letter also conveyed the following determination by HHS for finding 2021-035, 2020-039 on eligibility compliance: “The ACF believes the corrective actions taken or planned, as stated above, should prevent recurrence of this finding in the future. In addition, we recognize the continuous progression of the State’s actions to fully resolve this finding as the number of error cases and the amount of questioned costs have both significantly declined over the last 3 years. Therefore, the ACF will not pursue the questioned costs of $32 since the state has taken corrective actions that appear to have resulted in an amount of questioned costs that are immaterial.” The ACF recommended, “that the Department work with the auditors to determine an appropriate methodology that can be tested to ensure child care payments comply with Federal regulations.” The Department met with ACF and SAO on November 8, 2023, to discuss the ACF decision at which time ACF upheld the above statements that the finding was not substantiated. The Department is committed to collaborating with SAO to determine an appropriate methodology that identifies a sampling unit that can be used to accurately test compliance. The SAO maintained that the program is not auditable without child-level data. The Department does not currently have the staff and resources to develop and maintain the business process redesign, as well as the information technology initiatives necessary to meet the level of assurance as identified by SAO. In response to the auditor’s recommendations, the Department has submitted a budget request for the 2024 supplemental budget. If the request is funded, it would allow adjustments to include child-level data. Auditor’s Remarks The level of documentation needed to support grant expenditures is not established by our Office, but in title 45 of the U.S. Code of Federal Regulations and the state’s grant award. During the February 2022 meeting with HHS that the Department referenced in its response, the grantor stated the specific federal law the Department’s accounting procedures were noncompliant with was 45 CFR 98.67. We agree with the HHS management decision that our references to 2 CFR 200.53, 200.303, 200.403 and 200.410 in the prior finding were not correct. However, HHS adopted these same requirements in 45 CFR 75.2, 75.303, 75.403 and 75.410, respectfully. These requirements were all in place during the audit period. The proper references are included in this finding. In its response, the Department references previous findings related to the eligibility compliance requirement as a basis for asserting federal funds were spent properly. The requirements to determine whether a client is eligible to receive subsidized child care are different than the requirements to ensure the payments for those services are allowable, fall within each award’s period of performance and adequately supported. Without adequate transactional level payment data, our Office is unable to perform tests to verify the Department met these requirements. In addition, we also are unable to verify whether the Department complied with matching, level of effort and earmarking requirements, or that required financial information reported to the federal government was accurate. These matters are referenced in separate findings in our report. We disagree with the Department’s description of the meeting held with HHS program staff on November 8, 2023. The Department states HHS “upheld the above statements that the finding was not substantiated.” This is not accurate. During this meeting, HHS representatives conveyed the same message that they did in the management decision issued October 3, 2023. The finding was partially substantiated because the questioned costs identified in the audit would not be disallowed. The management decision states: “The ACF partially sustains the finding and recommendation. The ACF agrees with the auditor that the Department should strengthen internal controls to ensure payments to child care providers are allowable and properly supported.” “The ACF does not sustain a disallowance for the questioned costs in the amount of $271,353,409 representing the entire amount of the CCDF grant award. Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” We are not aware of what procedures ACF performed to conclude expenditures reported by the Department for fiscal year 2022 were spent only for allowable activities, were for allowable costs and met federal cost principles. We questioned all expenditures because, in our judgment, they were unauditable. Lastly, when the Washington State Legislature approved the Department’s 2023-25 biennial budget, it specified: “Funding in this subsection must be expended with internal controls that provide child-level detail for all transactions.” We reaffirm our finding and hope additional resources from the Legislature, to get down to child-level detail for all transactions, will resolve the auditing problems existing at the Department. We will review the status of the Department’s corrective action during our next audit. Applicable Laws and Regulations 45 U.S. Code of Federal Regulations (CFR) Part 75, section 303, Internal Controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 45 CFR Part 75, section 516, Audit findings, establishes reporting requirements for audit findings. Title 45 CFR, Section 98.66 – Availability of funds, states in part: (d) The following obligation and liquidation provisions apply to States and Territories: (1) Discretionary Fund allotments shall be obligated in the fiscal year in which funds are awarded or in the succeeding fiscal year. Unliquidated obligations as of the end of the succeeding fiscal year shall be liquidated within one year. (2) (i) Mandatory Funds for States requesting Matching Funds per § 98.55 shall be obligated in the fiscal year in which the funds are granted and are available until expended. (ii) Mandatory Funds for States that do not request Matching Funds are available until expended. (3) Both the Federal and non-Federal share of the Matching Fund shall be obligated in the fiscal year in which the funds are granted and liquidated no later than the end of the succeeding fiscal year. Title 45 CFR, Section 98.67 – Fiscal requirements, states: (a) Lead Agencies shall expend and account for CCDF funds in accordance with their own laws and procedures for expending and accounting for their own funds. (b) Unless otherwise specified in this part, contracts that entail the expenditure of CCDF funds shall comply with the laws and procedures generally applicable to expenditures by the contracting agency of its own funds. (c) Fiscal control and accounting procedures shall be sufficient to permit: (1) Preparation of reports required by the Secretary under this subpart and under subpart H; and (2) The tracking of funds to a level of expenditure adequate to establish that such funds have not been used in violation of the provisions of this part. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2023-062 The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with financial reporting requirements for the Child Care and Development Fund Cluster. Assistance Listing Number and Title: 93.575 Child Care and Development Block Grant 93.575 COVID-19 Child Care and Development Block Grant 93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund Federal Grantor Name: U.S. Department of Health and Human Service Federal Award/Contract Number: 2103WACCDF; 2103WACCDD; 2203WACCDF; 2203WACCDD; 2303WACCDF; 2303WACCDD; 2003WACCC3; 2103WACDC6; 2103WACSC6; 2103WACCC5 Pass-through Entity Name: None Pass-through Award/Contract Number: None Applicable Compliance Component: Reporting Known Questioned Cost Amount: None Prior Year Audit Finding: Yes, Finding 2022-044 Background The Department of Children, Youth, and Families administers the federal Child Care and Development Fund (CCDF) grants to help eligible working families pay for child care and fund improvements to child care quality. In fiscal year 2023, the Department spent about $547.2 million in federal funding. The Department is required to submit a quarterly ACF-696 financial report for each open grant. These reports contain information on expenditures for three CCDF funding sources: the Mandatory Fund, the Matching Fund, and the Discretionary Fund. The Department uses CCDF expenditures recorded in the state’s accounting system to compile and support the ACF-696 report. The U.S. Department of Health and Human Services (HHS), which oversees the CCDF program at the federal level, requires recipients to have accounting procedures that are sufficient for tracing grants to a level of expenditure adequate to show that they have been used in accordance with program requirements. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. In prior audits, we reported the Department did not have adequate internal controls over financial reporting requirements for the CCDF program. The prior finding numbers were 2022-044 and 2021-038. Description of Condition The Department did not have adequate internal controls over and did not comply with financial reporting requirements for the CCDF program. The Department’s accounting records must provide and support the financial information reported on ACF-696 reports. During the audit period, the Department’s grant management practice was to process expenditure transfers at the fund level without identifying which expenditures it transferred. Therefore, we could not rely on the data supporting the Department’s reported ACF-696 expenditures and could not test whether the reports were accurate and complete. This condition is also referenced in audit finding 2023-058. We consider these internal control deficiencies to be a material weakness, which led to material noncompliance. Cause of Condition The Department is required to maintain sufficient documentation for each payment it makes using federal dollars. The Department’s accounting practices prevent it from meeting this requirement. In fiscal year 2021, the Department informed our Office that it had implemented what management referred to as fund-level accounting. This consisted of making significant accounting adjustments between funding sources in its general ledger without identifying the underlying transactions in the payment system that supported them. This affected all populations of childcare expenditures for every month of the fiscal year. HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant. Effect of Condition By not complying with requirements in federal law to maintain adequate supporting documentation for expenditures, the Department created a condition that made it impossible for our Office to audit the CCDF program expenditures reported on the ACF-696 financial report. Recommendations We recommend the Department design and implement internal controls to ensure the ACF-696 report is supported with transaction-level data that is sufficient to comply with federal law and state rules. Department’s Response The Department has managed the CCDF program since 2019, prior to that it was managed by the Department of Social and Health Services and the Department of Early Learning. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF grants to eligible clients and allowable activities in compliance with 45 CFR 98.67. This process consists of making grant level adjustments between allowable grant sources to properly spend grant dollars within the allowable period of performance and ensure level of effort and matching requirements. The Department’s grant adjustments were processed based on eligible clients and allowable activities and did not include child-level data as required by SAO. The Department held an informal meeting on February 23, 2022, with HHS representative, the State Auditor’s Office and the Office of Financial Management. The intent was to obtain the grantor’s perspective in whether proper grant accounting required the use of child-level data. HHS stated they would not offer an opinion until they received the completed finding from the state. However, the Cause of Condition of finding 2021-033 stated, “HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant.” The Department does not agree with SAO’s interpretation of the meeting outcome. In the area of CCDF eligibility, for state fiscal year 2021, the SAO also issued finding 2021-035, with questioned cost of $32 and in state fiscal year 2022, finding 2022-008 (temporary number) with no questioned costs. There were no other findings or exit items in the area of eligibility determination or the cost allocation of funds. Given that eligibility or cost allocation is not an area of concern and transfers were processed between CCDF source of funds with the same eligibility requirements, the Department is confident CCDF funding was spent appropriately within federal regulations. The Department received a management decision letter dated October 3, 2023, from HHS for finding 2021-033 (2020-038) which states: “the ACF noted that the auditor raised concern about the Department’s accounting procedures and efforts made to trace expenditures at the transaction-level. As the basis for the finding, the auditor used CFRs (200.53, 200.303, 200.403, 200.410) that do not apply to CCDF. Federal regulations allow Lead Agencies to expend and account for CCDF funds in accordance with their own procedures.” In addition, ACF did not sustain the disallowance of questioned costs and stated: “Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” The management decision letter also conveyed the following determination by HHS for finding 2021-035, 2020-039 on eligibility compliance: “The ACF believes the corrective actions taken or planned, as stated above, should prevent recurrence of this finding in the future. In addition, we recognize the continuous progression of the State’s actions to fully resolve this finding as the number of error cases and the number of questioned costs have both significantly declined over the last 3 years. Therefore, the ACF will not pursue the questioned costs of $32 since the state has taken corrective actions that appear to have resulted in an amount of questioned costs that are immaterial.” The ACF recommended, “that the Department work with the auditors to determine an appropriate methodology that can be tested to ensure childcare payments comply with Federal regulations.” The Department met with ACF and SAO on November 8, 2023, to discuss the ACF decision at which time ACF upheld the above statements that the finding was not substantiated. The Department is committed to collaborating with SAO to determine an appropriate methodology that identifies a sampling unit that can be used to accurately test compliance. The SAO maintained that the program is not auditable without child-level data. The Department does not currently have the staff and resources to develop and maintain the business process redesign, as well as the information technology initiatives necessary to meet the level of assurance as identified by SAO. In response to the auditor’s recommendations, the Department has submitted a budget request for the 2024 supplemental budget. If the request is funded, it would allow adjustments to include child-level data. Auditor’s Remarks The level of documentation needed to support grant expenditures is not established by our Office, but in title 45 of the U.S. Code of Federal Regulations and the state’s grant award. During the February 2022 meeting with HHS that the Department referenced in its response, the grantor stated the specific federal law the Department’s accounting procedures were noncompliant with was 45 CFR 98.67. We agree with the HHS management decision that our references to 2 CFR 200.53, 200.303, 200.403 and 200.410 in the prior finding were not correct. However, HHS adopted these same requirements in 45 CFR 75.2, 75.303, 75.403 and 75.410, respectfully. These requirements were all in place during the audit period. The proper references are included in this finding. In its response, the Department references previous findings related to the eligibility compliance requirement as a basis for asserting federal funds were spent properly. The requirements to determine whether a client is eligible to receive subsidized child care are different than the requirements to ensure the payments for those services are allowable, fall within each award’s period of performance and adequately supported. Without adequate transactional level payment data, our Office is unable to perform tests to verify the Department met these requirements. In addition, we also are unable to verify whether the Department complied with matching, level of effort and earmarking requirements, or that required financial information reported to the federal government was accurate. These matters are referenced in separate findings in our report. We disagree with the Department’s description of the meeting held with HHS program staff on November 8, 2023. The Department states HHS “upheld the above statements that the finding was not substantiated.” This is not accurate. During this meeting, HHS representatives conveyed the same message that they did in the management decision issued October 3, 2023. The finding was partially substantiated because the questioned costs identified in the audit would not be disallowed. The management decision states: “The ACF partially sustains the finding and recommendation. The ACF agrees with the auditor that the Department should strengthen internal controls to ensure payments to child care providers are allowable and properly supported.” “The ACF does not sustain a disallowance for the questioned costs in the amount of $271,353,409 representing the entire amount of the CCDF grant award. Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” We are not aware of what procedures ACF performed to conclude expenditures reported by the Department for fiscal year 2022 were spent only for allowable activities, were for allowable costs and met federal cost principles. We questioned all expenditures because, in our judgment, they were unauditable. Lastly, when the Washington State Legislature approved the Department’s 2023-25 biennial budget, it specified: “Funding in this subsection must be expended with internal controls that provide child-level detail for all transactions.” We reaffirm our finding and hope additional resources from the Legislature, to get down to child-level detail for all transactions, will resolve the auditing problems existing at the Department. We will review the status of the Department’s corrective action during our next audit. Applicable Laws and Regulations 45 U.S. Code of Federal Regulations (CFR) Part 75, section 303, Internal Controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 45 CFR Part 75, section 516, Audit findings, establishes reporting requirements for audit findings. Title 45 CFR, Section 98.67 – Fiscal requirements, states: (a) Lead Agencies shall expend and account for CCDF funds in accordance with their own laws and procedures for expending and accounting for their own funds. (b) Unless otherwise specified in this part, contracts that entail the expenditure of CCDF funds shall comply with the laws and procedures generally applicable to expenditures by the contracting agency of its own funds. (c) Fiscal control and accounting procedures shall be sufficient to permit: (1) Preparation of reports required by the Secretary under this subpart and under subpart H; and (2) The tracking of funds to a level of expenditure adequate to establish that such funds have not been used in violation of the provisions of this part. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2023-058 The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with requirements to ensure payments to child care providers for the Child Care and Development Fund Cluster programs were allowable and properly supported. Assistance Listing Number and Title: 93.575 Child Care and Development Block Grant 93.575 COVID-19 Child Care and Development Block Grant 93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund Federal Grantor Name: U.S. Department of Health and Human Services Federal Award/Contract Number: 2103WACCDF; 2103WACCDD; 2203WACCDF; 2203WACCDD; 2303WACCDF; 2303WACCDD; 2003WACCC3; 2103WACDC6; 2103WACSC6; 2103WACCC5 Pass-through Entity Name: None Pass-through Award/Contract Number: None Applicable Compliance Component: Activities Allowed or Unallowed Allowable Costs/Cost Principles Known Questioned Cost Amount: $356,042,172 Prior Year Audit Finding: Yes, Finding 2022-041 Background The Department of Children, Youth, and Families administers the federal Child Care and Development Fund (CCDF) grants to help eligible working families pay for child care and fund improvements to child care quality. In fiscal year 2023, the Department spent about $547.2 million in federal funding. The Department is responsible for establishing policies to ensure payments to providers for child care services are allowable. In fiscal year 2023, the Department spent more than $356 million on monthly child care subsidy payments to child care providers. There are three child care provider types: licensed centers, licensed family homes, and licensed exempt providers referred to as Family, Friends and Neighbor providers. The Department uses the Social Service Payment System (SSPS) to process the payments it makes to child care providers. The system allocates payments to various funding sources, based on the eligibility of the client. These funding sources include multiple federal programs, multiple CCDF federal grant awards, and state funding. The Department uploads the SSPS payment data into the state’s accounting system at a summary level based on the various funding sources. There is always a need to transfer the funding sources for some payments throughout the year to manage federal and state funds properly. In prior audit periods up until fiscal year 2021, the Department prepared supporting documentation for transfers that included details of what payments it was transferring. The purpose of documenting this detail was to maintain proper support for federal expenditures. The Department of Health and Human Services (HHS), which oversees the CCDF program at the federal level, requires recipients have accounting procedures that are sufficient for tracing grants to a level of expenditure adequate to show that they have been used in accordance with program requirements. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. In prior audits, we reported the Department did not have adequate internal controls over and did not comply with requirements to ensure payments to child care providers were allowable and properly supported. We have reported this condition since 2005. The most recent audit finding numbers were 2022-041, 2021-033, 2020-038, 2019-035, 2018–034, 2017-024, 2016-021, 2015-023, 2014-023, 2013-016, 12-28, 11-23, 10-31, 9-12 and 8–13. Description of Condition The Department did not have adequate internal controls over and did not comply with requirements to ensure payments to child care providers for the CCDF programs were allowable and properly supported. In fiscal year 2021, management informed us that the Department changed its grant management practices to process expenditure transfers at the grant level. This new process made the original expenditure coding in SSPS inaccurate and unreliable for testing. As a result, we could not trace the federal funds to a level of expenditure adequate to establish whether the Department spent CCDF funds in accordance with federal and state regulations. Further, this meant we could not test the Department’s payments to child care providers for compliance with activities allowed and cost principles. By processing these adjustments at the fund level, the Department invalidated the transaction-level documentation of the original child care expenditure in SSPS and did not identify the new allocation at the payment level. Additionally, the Department transferred some of these child care expenditures more than once at the fund level, making the underlying data increasingly unreliable with each transfer. We consider these internal control deficiencies to be a material weakness, which led to material noncompliance. Cause of Condition The Department is required to maintain sufficient documentation for each payment it makes with federal dollars. The Department’s accounting practices prevent it from meeting this requirement. The Department implemented what management referred to as fund-level accounting. This consisted of making significant accounting adjustments between funding sources in its general ledger without identifying the underlying transactions in the payment system that supported the adjustments. This affected all populations of child care expenditures for every month of the fiscal year. HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant. Effect of Condition By not complying with requirements in federal law to maintain adequate supporting documentation for expenditures, the Department created a condition that made it impossible for our Office to audit the federal dollars it used for payments to child care providers. Because we could not test transaction-level detail, we also could not determine whether the issues we identified in prior audits had improved or worsened, including the Department’s lack of adequate internal controls and significant rate of noncompliance for payments to child care providers. The total amount of known child care payments with federal CCDF funds in the audit period was $356,042,172. The Department also partially funded these payments with an additional $48,941,302 in state dollars. Because the Department did not comply with HHS requirements to allow for the tracing of grant expenditures to a payment level, we are questioning all $356,042,172 in federal program costs the Department incurred during the audit period. The payments the Department partially paid with state funds are not included in the federal questioned costs. We question costs when we find an agency has not complied with grant regulations or when it does not have adequate documentation to support its expenditures. Recommendations We recommend the Department: • Design and implement internal controls to ensure transaction-level data is sufficient to comply with federal law and state rules • Consult with the grantor to discuss whether the questioned costs identified in the audit should be repaid Department’s Response The Department has managed the CCDF program since 2019, prior to that it was managed by the Department of Social and Health Services and the Department of Early Learning. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF grants to eligible clients and allowable activities in compliance with 45 CFR 98.67. This process consists of making grant level adjustments between allowable grant sources to properly spend grant dollars within the allowable period of performance and ensure level of effort and matching requirements. The Department’s grant adjustments were processed based on eligible clients and allowable activities and did not include child-level data as required by SAO. The Department held an informal meeting on February 23, 2022, with HHS representative, the State Auditor’s Office and the Office of Financial Management. The intent was to obtain the grantor’s perspective in whether proper grant accounting required the use of child-level data. HHS stated they would not offer an opinion until they received the completed finding from the state. However, the Cause of Condition of finding 2021-033 stated, “HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant.” The Department does not agree with SAO’s interpretation of the meeting outcome. In the area of CCDF eligibility, for state fiscal year 2021, the SAO also issued finding 2021-035, with questioned cost of $32 and in state fiscal year 2022, finding 2022-008 (temporary number) with no questioned costs. There were no other findings or exit items in the area of eligibility determination or the cost allocation of funds. Given that eligibility or cost allocation is not an area of concern and transfers were processed between CCDF source of funds with the same eligibility requirements, the Department is confident CCDF funding was spent appropriately within federal regulations. The Department received a management decision letter dated October 3, 2023, from HHS for finding 2021-033 (2020-038) which states: “the ACF noted that the auditor raised concern about the Department’s accounting procedures and efforts made to trace expenditures at the transaction-level. As the basis for the finding, the auditor used CFRs (200.53, 200.303, 200.403, 200.410) that do not apply to CCDF. Federal regulations allow Lead Agencies to expend and account for CCDF funds in accordance with their own procedures.” In addition, ACF did not sustain the disallowance of questioned costs and stated: “Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” The management decision letter also conveyed the following determination by HHS for finding 2021-035, 2020-039 on eligibility compliance: “The ACF believes the corrective actions taken or planned, as stated above, should prevent recurrence of this finding in the future. In addition, we recognize the continuous progression of the State’s actions to fully resolve this finding as the number of error cases and the amount of questioned costs have both significantly declined over the last 3 years. Therefore, the ACF will not pursue the questioned costs of $32 since the state has taken corrective actions that appear to have resulted in an amount of questioned costs that are immaterial.” The ACF recommended, “that the Department work with the auditors to determine an appropriate methodology that can be tested to ensure child care payments comply with Federal regulations.” The Department met with ACF and SAO on November 8, 2023, to discuss the ACF decision at which time ACF upheld the above statements that the finding was not substantiated. The Department is committed to collaborating with SAO to determine an appropriate methodology that identifies a sampling unit that can be used to accurately test compliance. The SAO maintained that the program is not auditable without child-level data. The Department does not currently have the staff and resources to develop and maintain the business process redesign, as well as the information technology initiatives necessary to meet the level of assurance as identified by SAO. In response to the auditor’s recommendations, the Department has submitted a budget request for the 2024 supplemental budget. If the request is funded, it would allow adjustments to include child-level data. Auditor’s Remarks The level of documentation needed to support grant expenditures is not established by our Office, but in title 45 of the U.S. Code of Federal Regulations and the state’s grant award. During the February 2022 meeting with HHS that the Department referenced in its response, the grantor stated the specific federal law the Department’s accounting procedures were noncompliant with was 45 CFR 98.67. We agree with the HHS management decision that our references to 2 CFR 200.53, 200.303, 200.403 and 200.410 in the prior finding were not correct. However, HHS adopted these same requirements in 45 CFR 75.2, 75.303, 75.403 and 75.410, respectfully. These requirements were all in place during the audit period. The proper references are included in this finding. In its response, the Department references previous findings related to the eligibility compliance requirement as a basis for asserting federal funds were spent properly. The requirements to determine whether a client is eligible to receive subsidized child care are different than the requirements to ensure the payments for those services are allowable, fall within each award’s period of performance and adequately supported. Without adequate transactional level payment data, our Office is unable to perform tests to verify the Department met these requirements. In addition, we also are unable to verify whether the Department complied with matching, level of effort and earmarking requirements, or that required financial information reported to the federal government was accurate. These matters are referenced in separate findings in our report. We disagree with the Department’s description of the meeting held with HHS program staff on November 8, 2023. The Department states HHS “upheld the above statements that the finding was not substantiated.” This is not accurate. During this meeting, HHS representatives conveyed the same message that they did in the management decision issued October 3, 2023. The finding was partially substantiated because the questioned costs identified in the audit would not be disallowed. The management decision states: “The ACF partially sustains the finding and recommendation. The ACF agrees with the auditor that the Department should strengthen internal controls to ensure payments to child care providers are allowable and properly supported.” “The ACF does not sustain a disallowance for the questioned costs in the amount of $271,353,409 representing the entire amount of the CCDF grant award. Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” We are not aware of what procedures ACF performed to conclude expenditures reported by the Department for fiscal year 2022 were spent only for allowable activities, were for allowable costs and met federal cost principles. We questioned all expenditures because, in our judgment, they were unauditable. Lastly, when the Washington State Legislature approved the Department’s 2023-25 biennial budget, it specified: “Funding in this subsection must be expended with internal controls that provide child-level detail for all transactions.” We reaffirm our finding and hope additional resources from the Legislature, to get down to child-level detail for all transactions, will resolve the auditing problems existing at the Department. We will review the status of the Department’s corrective action during our next audit. Applicable Laws and Regulations 45 U.S. Code of Federal Regulations (CFR) Part 75, section 2, Definitions, includes the definition of improper payment. 45 CFR Part 75, section 303, Internal Controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. 45 CFR Part 75, section 403, Factors Affecting Allowability of Costs. 45 CFR Part 75, section 410, Collection of Unallowable Costs 45 CFR Part 75, section 516, Audit findings, establishes reporting requirements for audit findings. Title 45 CFR, Section 98.67 – Fiscal requirements, states: (a) Lead Agencies shall expend and account for CCDF funds in accordance with their own laws and procedures for expending and accounting for their own funds. (b) Unless otherwise specified in this part, contracts that entail the expenditure of CCDF funds shall comply with the laws and procedures generally applicable to expenditures by the contracting agency of its own funds. (c) Fiscal control and accounting procedures shall be sufficient to permit: (1) Preparation of reports required by the Secretary under this subpart and under subpart H; and (2) The tracking of funds to a level of expenditure adequate to establish that such funds have not been used in violation of the provisions of this part. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2023-060 The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with matching, level of effort, and earmarking requirements for the Child Care and Development Fund Cluster. Assistance Listing Number and Title: 93.575 Child Care and Development Block Grant 93.575 COVID-19 Child Care and Development Block Grant 93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund Federal Grantor Name: U.S. Department of Health and Human Services Federal Award/Contract Number: 2103WACCDF; 2103WACCDD; 2203WACCDF; 2203WACCDD; 2303WACCDF; 2303WACCDD; 2003WACCC3; 2103WACDC6; 2103WACSC6; 2103WACCC5 Pass-through Entity Name: None Pass-through Award/Contract Number: None Applicable Compliance Component: Matching, Level of Effort, Earmarking Known Questioned Cost Amount: None Prior Year Audit Finding: Yes, Finding 2022-042 Background The Department of Children, Youth, and Families administers the federal Child Care and Development Fund (CCDF) grants to help eligible working families pay for child care and fund improvements to child care quality. In fiscal year 2023, the Department spent about $547.2 million in federal funding. The CCDF consists of three distinct funding sources: Discretionary Fund, Mandatory Fund, and Matching Fund. Additionally, under the Temporary Assistance for Needy Families (TANF) program, the Department may transfer TANF funds to the CCDF, which are then treated as Discretionary Funds. The Department is instructed how to spend this federal money. For the Department to receive its allotted share of the Matching Fund, it must meet the Maintenance of Effort (MOE) requirement and match the federal Matching Fund claimed with state expenditures at the Federal Medical Assistance Percentage rate for the applicable fiscal year. The Department must also meet earmarking requirements for expenditures for administrative and quality activities. The U.S. Department of Health and Human Services (HHS), which oversees the CCDF program at the federal level, requires recipients have accounting procedures that are sufficient for tracing grants to a level of expenditure adequate to show that they have been used in accordance with program requirements. Department staff run monthly and quarterly expenditure reports from the accounting system to track requirements over matching, level of effort, and earmarking for each open grant award. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. In prior audits, we reported the Department did not have adequate internal controls over matching, level of effort, and earmarking requirements for the CCDF Cluster programs. The prior audit finding numbers were 2022-042, 2021-036, and 2020-040. Description of Condition The Department did not have adequate internal controls over and did not comply with matching, level of effort, and earmarking requirements for the CCDF programs. The Department’s accounting records should be used to verify it has met matching, level of effort, and earmarking requirements. In fiscal year 2021, management informed us that the Department changed its grant management practices to process expenditure transfers at the grant level. This new process made the original expenditure coding in the payment system inaccurate and unreliable for testing. Without identifying which expenditures it transferred, the Department’s monitoring is insufficient for properly managing matching, level of effort, and earmarking requirements. Our Office could not rely on the data supporting the Department’s expenditures or verify that the accounting records were accurate. As a result, we could not trace the federal funds to a level of expenditure adequate to establish whether the Department spent CCDF funds in accordance with federal and state regulations. Further, this meant we could not test the Department’s payments for compliance with matching, level of effort, and earmarking requirements. By processing these adjustments at the fund level, the Department invalidated the transaction-level documentation of the original child care expenditure in the payment system, and did not identify the new allocation at the payment level. Additionally, the Department transferred some of these child care expenditures more than once at the fund level, making the underlying data increasingly unreliable with each transfer. This condition is also referenced in audit finding 2023-058. We consider these internal control deficiencies to be a material weakness, which led to material noncompliance. Cause of Condition The Department is required to maintain sufficient documentation for each payment it makes with federal dollars. The Department’s accounting practices prevent it from meeting this requirement. In fiscal year 2021, the Department informed our Office that it had implemented what management referred to as fund-level accounting. This consisted of making significant accounting adjustments between funding sources in its general ledger without identifying the underlying transactions in the payment system that supported the adjustments. This affected all populations of child care expenditures for every month of the fiscal year. HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant. Effect of Condition By not complying with requirements in federal law to maintain adequate supporting documentation for expenditures the Department created a condition that made it impossible for our Office to determine if it had met matching, level of effort, and earmarking requirements. Recommendations We recommend the Department: • Design and implement internal controls to ensure transaction-level data is sufficient to comply with federal law and state rules • Develop effective ongoing monitoring procedures Department’s Response The Department has managed the CCDF program since 2019, prior to that it was managed by the Department of Social and Health Services and the Department of Early Learning. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF grants to eligible clients and allowable activities in compliance with 45 CFR 98.67. This process consists of making grant level adjustments between allowable grant sources to properly spend grant dollars within the allowable period of performance and ensure level of effort and matching requirements. The Department’s grant adjustments were processed based on eligible clients and allowable activities and did not include child-level data as required by SAO. The Department held an informal meeting on February 23, 2022, with HHS representative, the State Auditor’s Office and the Office of Financial Management. The intent was to obtain the grantor’s perspective in whether proper grant accounting required the use of child-level data. HHS stated they would not offer an opinion until they received the completed finding from the state. However, the Cause of Condition of finding 2021-033 stated, “HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant.” The Department does not agree with SAO’s interpretation of the meeting outcome. In the area of CCDF eligibility, for state fiscal year 2021, the SAO also issued finding 2021-035, with questioned cost of $32 and in state fiscal year 2022, finding 2022-008 (temporary number) with no questioned costs. There were no other findings or exit items in the area of eligibility determination or the cost allocation of funds. Given that eligibility or cost allocation is not an area of concern and transfers were processed between CCDF source of funds with the same eligibility requirements, the Department is confident CCDF funding was spent appropriately within federal regulations. The Department received a management decision letter dated October 3, 2023, from HHS for finding 2021-033 (2020-038) which states: “the ACF noted that the auditor raised concern about the Department’s accounting procedures and efforts made to trace expenditures at the transaction-level. As the basis for the finding, the auditor used CFRs (200.53, 200.303, 200.403, 200.410) that do not apply to CCDF. Federal regulations allow Lead Agencies to expend and account for CCDF funds in accordance with their own procedures.” In addition, ACF did not sustain the disallowance of questioned costs and stated: “Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” The management decision letter also conveyed the following determination by HHS for finding 2021-035, 2020-039 on eligibility compliance: “The ACF believes the corrective actions taken or planned, as stated above, should prevent recurrence of this finding in the future. In addition, we recognize the continuous progression of the State’s actions to fully resolve this finding as the number of error cases and the amount of questioned costs have both significantly declined over the last 3 years. Therefore, the ACF will not pursue the questioned costs of $32 since the state has taken corrective actions that appear to have resulted in an amount of questioned costs that are immaterial.” The ACF recommended, “that the Department work with the auditors to determine an appropriate methodology that can be tested to ensure child care payments comply with Federal regulations.” The Department met with ACF and SAO on November 8, 2023, to discuss the ACF decision at which time ACF upheld the above statements that the finding was not substantiated. The Department is committed to collaborating with SAO to determine an appropriate methodology that identifies a sampling unit that can be used to accurately test compliance. The SAO maintained that the program is not auditable without child-level data. The Department does not currently have the staff and resources to develop and maintain the business process redesign, as well as the information technology initiatives necessary to meet the level of assurance as identified by SAO. In response to the auditor’s recommendations, the Department has submitted a budget request for the 2024 supplemental budget. If the request is funded, it would allow adjustments to include child-level data. Auditor’s Remarks The level of documentation needed to support grant expenditures is not established by our Office, but in title 45 of the U.S. Code of Federal Regulations and the state’s grant award. During the February 2022 meeting with HHS that the Department referenced in its response, the grantor stated the specific federal law the Department’s accounting procedures were noncompliant with was 45 CFR 98.67. We agree with the HHS management decision that our references to 2 CFR 200.53, 200.303, 200.403 and 200.410 in the prior finding were not correct. However, HHS adopted these same requirements in 45 CFR 75.2, 75.303, 75.403 and 75.410, respectfully. These requirements were all in place during the audit period. The proper references are included in this finding. In its response, the Department references previous findings related to the eligibility compliance requirement as a basis for asserting federal funds were spent properly. The requirements to determine whether a client is eligible to receive subsidized child care are different than the requirements to ensure the payments for those services are allowable, fall within each award’s period of performance and adequately supported. Without adequate transactional level payment data, our Office is unable to perform tests to verify the Department met these requirements. In addition, we also are unable to verify whether the Department complied with matching, level of effort and earmarking requirements, or that required financial information reported to the federal government was accurate. These matters are referenced in separate findings in our report. We disagree with the Department’s description of the meeting held with HHS program staff on November 8, 2023. The Department states HHS “upheld the above statements that the finding was not substantiated.” This is not accurate. During this meeting, HHS representatives conveyed the same message that they did in the management decision issued October 3, 2023. The finding was partially substantiated because the questioned costs identified in the audit would not be disallowed. The management decision states: “The ACF partially sustains the finding and recommendation. The ACF agrees with the auditor that the Department should strengthen internal controls to ensure payments to child care providers are allowable and properly supported.” “The ACF does not sustain a disallowance for the questioned costs in the amount of $271,353,409 representing the entire amount of the CCDF grant award. Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” We are not aware of what procedures ACF performed to conclude expenditures reported by the Department for fiscal year 2022 were spent only for allowable activities, were for allowable costs and met federal cost principles. We questioned all expenditures because, in our judgment, they were unauditable. Lastly, when the Washington State Legislature approved the Department’s 2023-25 biennial budget, it specified: “Funding in this subsection must be expended with internal controls that provide child-level detail for all transactions.” We reaffirm our finding and hope additional resources from the Legislature, to get down to child-level detail for all transactions, will resolve the auditing problems existing at the Department. We will review the status of the Department’s corrective action during our next audit. Applicable Laws and Regulations 45 U.S. Code of Federal Regulations (CFR) Part 75, section 303, Internal Controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 45 CFR Part 75, section 516, Audit findings, establishes reporting requirements for audit findings. Title 45 CFR, Section 98.67 – Fiscal requirements, states: (a) Lead Agencies shall expend and account for CCDF funds in accordance with their own laws and procedures for expending and accounting for their own funds. (b) Unless otherwise specified in this part, contracts that entail the expenditure of CCDF funds shall comply with the laws and procedures generally applicable to expenditures by the contracting agency of its own funds. (c) Fiscal control and accounting procedures shall be sufficient to permit: (1) Preparation of reports required by the Secretary under this subpart and under subpart H; and (2) The tracking of funds to a level of expenditure adequate to establish that such funds have not been used in violation of the provisions of this part. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2023-061 The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with period of performance requirements for the Child Care and Development Fund Cluster. Assistance Listing Number and Title: 93.575 Child Care and Development Block Grant 93.575 COVID-19 Child Care and Development Block Grant 93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund Federal Grantor Name: U.S. Department of Health and Human Services Federal Award/Contract Number: 2103WACCDF; 2103WACCDD; 2203WACCDF; 2203WACCDD; 2303WACCDF; 2303WACCDD; 2003WACCC3; 2103WACDC6; 2103WACSC6; 2103WACCC5 Pass-through Entity Name: None Pass-through Award/Contract Number: None Applicable Compliance Component: Period of Performance Known Questioned Cost Amount: None Prior Year Audit Finding: Yes, Finding 2022-043 Background The Department of Children, Youth, and Families administers the federal Child Care and Development Fund (CCDF) grants to help eligible working families pay for child care and fund improvements to child care quality. In fiscal year 2023, the Department spent about $547.2 million in federal funding. Each federal grant specifies a performance period during which recipients must obligate and liquidate program costs. These periods typically align with the federal fiscal year of October 1 through September 30. Payments for costs charged before a grant’s beginning date or after the ending date are not allowed without the grantor’s prior approval. The CCDF consists of three distinct funding sources: Discretionary Fund, Mandatory Fund, and Matching Fund. Each of these funds has specific period of performance requirements established in federal regulation (45 CFR § 98.60(d)): • Discretionary Funds must be obligated by the end of the succeeding fiscal year after award and expended by the end of the third fiscal year after award. • Mandatory Funds must be obligated by the end of the fiscal year in which they are awarded if the state also requests Matching Funds. If no Matching Funds are requested for the fiscal year, then the Mandatory Funds are available until liquidated. • Matching Funds must be obligated by the end of the fiscal year in which they are awarded and liquidated by the end of the succeeding fiscal year after award. During the audit period, the Department also received supplemental funds under the Coronavirus Aid, Relief, and Economic Security (CARES) and the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Acts. These funds are treated as Discretionary Funds, however, they have their own specific obligation and liquidation timeframes. The U.S. Department of Health and Human Services (HHS), which oversees the CCDF at the federal level, requires recipients to have accounting procedures that are sufficient for tracing grants to a level of expenditure adequate to show that they have been used in accordance with program requirements. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. In prior audits, we reported the Department did not have adequate internal controls over period of performance requirements for the CCDF program. The prior finding numbers were 2022-043, 2021-037, and 2020-041. Description of Condition The Department did not have adequate internal controls over and did not comply with period of performance requirements for the CCDF program. Our Office uses the Department’s accounting records to verify it has met the period of performance requirements. In fiscal year 2021, management informed us that the Department changed its grant management practices to process expenditure transfers at the grant level. This new process made the original expenditures coded in the payment system inaccurate and unreliable for audit testing. As a result, we could not trace the federal funds to a level of expenditure adequate to establish whether the Department spent CCDF funds in accordance with federal and state regulations. Further, this meant we could not test the Department’s payments for compliance with period of performance requirements. This condition is also referenced in audit finding 2023-058. We consider these internal control deficiencies to be a material weakness, which led to material noncompliance. Cause of Condition The Department is required to maintain sufficient documentation for each payment it makes with federal dollars. The Department’s accounting practices prevent it from meeting this requirement. The Department implemented what management referred to as fund-level accounting. This consisted of making significant accounting adjustments between funding sources in its general ledger without identifying the underlying transactions in the payment system that supported the adjustments. This affected all populations of child care expenditures for every month of the fiscal year. HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant. Effect of Condition By not complying with requirements in federal law to maintain adequate supporting documentation for expenditures, the Department created a condition that made it impossible for our Office to determine if it materially met the period of performance requirements. Furthermore, without adequate internal controls in place, the Department is at a higher risk of making improper payments with grant funds. Recommendations We recommend the Department: • Design and implement internal controls to ensure transaction-level data is sufficient to comply with federal law and state rules • Develop written policies and procedures over federal period of performance requirements Department’s Response The Department has managed the CCDF program since 2019, prior to that it was managed by the Department of Social and Health Services and the Department of Early Learning. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF grants to eligible clients and allowable activities in compliance with 45 CFR 98.67. This process consists of making grant level adjustments between allowable grant sources to properly spend grant dollars within the allowable period of performance and ensure level of effort and matching requirements. The Department’s grant adjustments were processed based on eligible clients and allowable activities and did not include child-level data as required by SAO. The Department held an informal meeting on February 23, 2022, with HHS representative, the State Auditor’s Office and the Office of Financial Management. The intent was to obtain the grantor’s perspective in whether proper grant accounting required the use of child-level data. HHS stated they would not offer an opinion until they received the completed finding from the state. However, the Cause of Condition of finding 2021-033 stated, “HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant.” The Department does not agree with SAO’s interpretation of the meeting outcome. In the area of CCDF eligibility, for state fiscal year 2021, the SAO also issued finding 2021-035, with questioned cost of $32 and in state fiscal year 2022, finding 2022-008 (temporary number) with no questioned costs. There were no other findings or exit items in the area of eligibility determination or the cost allocation of funds. Given that eligibility or cost allocation is not an area of concern and transfers were processed between CCDF source of funds with the same eligibility requirements, the Department is confident CCDF funding was spent appropriately within federal regulations. The Department received a management decision letter dated October 3, 2023, from HHS for finding 2021-033 (2020-038) which states: “the ACF noted that the auditor raised concern about the Department’s accounting procedures and efforts made to trace expenditures at the transaction-level. As the basis for the finding, the auditor used CFRs (200.53, 200.303, 200.403, 200.410) that do not apply to CCDF. Federal regulations allow Lead Agencies to expend and account for CCDF funds in accordance with their own procedures.” In addition, ACF did not sustain the disallowance of questioned costs and stated: “Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” The management decision letter also conveyed the following determination by HHS for finding 2021-035, 2020-039 on eligibility compliance: “The ACF believes the corrective actions taken or planned, as stated above, should prevent recurrence of this finding in the future. In addition, we recognize the continuous progression of the State’s actions to fully resolve this finding as the number of error cases and the amount of questioned costs have both significantly declined over the last 3 years. Therefore, the ACF will not pursue the questioned costs of $32 since the state has taken corrective actions that appear to have resulted in an amount of questioned costs that are immaterial.” The ACF recommended, “that the Department work with the auditors to determine an appropriate methodology that can be tested to ensure child care payments comply with Federal regulations.” The Department met with ACF and SAO on November 8, 2023, to discuss the ACF decision at which time ACF upheld the above statements that the finding was not substantiated. The Department is committed to collaborating with SAO to determine an appropriate methodology that identifies a sampling unit that can be used to accurately test compliance. The SAO maintained that the program is not auditable without child-level data. The Department does not currently have the staff and resources to develop and maintain the business process redesign, as well as the information technology initiatives necessary to meet the level of assurance as identified by SAO. In response to the auditor’s recommendations, the Department has submitted a budget request for the 2024 supplemental budget. If the request is funded, it would allow adjustments to include child-level data. Auditor’s Remarks The level of documentation needed to support grant expenditures is not established by our Office, but in title 45 of the U.S. Code of Federal Regulations and the state’s grant award. During the February 2022 meeting with HHS that the Department referenced in its response, the grantor stated the specific federal law the Department’s accounting procedures were noncompliant with was 45 CFR 98.67. We agree with the HHS management decision that our references to 2 CFR 200.53, 200.303, 200.403 and 200.410 in the prior finding were not correct. However, HHS adopted these same requirements in 45 CFR 75.2, 75.303, 75.403 and 75.410, respectfully. These requirements were all in place during the audit period. The proper references are included in this finding. In its response, the Department references previous findings related to the eligibility compliance requirement as a basis for asserting federal funds were spent properly. The requirements to determine whether a client is eligible to receive subsidized child care are different than the requirements to ensure the payments for those services are allowable, fall within each award’s period of performance and adequately supported. Without adequate transactional level payment data, our Office is unable to perform tests to verify the Department met these requirements. In addition, we also are unable to verify whether the Department complied with matching, level of effort and earmarking requirements, or that required financial information reported to the federal government was accurate. These matters are referenced in separate findings in our report. We disagree with the Department’s description of the meeting held with HHS program staff on November 8, 2023. The Department states HHS “upheld the above statements that the finding was not substantiated.” This is not accurate. During this meeting, HHS representatives conveyed the same message that they did in the management decision issued October 3, 2023. The finding was partially substantiated because the questioned costs identified in the audit would not be disallowed. The management decision states: “The ACF partially sustains the finding and recommendation. The ACF agrees with the auditor that the Department should strengthen internal controls to ensure payments to child care providers are allowable and properly supported.” “The ACF does not sustain a disallowance for the questioned costs in the amount of $271,353,409 representing the entire amount of the CCDF grant award. Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” We are not aware of what procedures ACF performed to conclude expenditures reported by the Department for fiscal year 2022 were spent only for allowable activities, were for allowable costs and met federal cost principles. We questioned all expenditures because, in our judgment, they were unauditable. Lastly, when the Washington State Legislature approved the Department’s 2023-25 biennial budget, it specified: “Funding in this subsection must be expended with internal controls that provide child-level detail for all transactions.” We reaffirm our finding and hope additional resources from the Legislature, to get down to child-level detail for all transactions, will resolve the auditing problems existing at the Department. We will review the status of the Department’s corrective action during our next audit. Applicable Laws and Regulations 45 U.S. Code of Federal Regulations (CFR) Part 75, section 303, Internal Controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 45 CFR Part 75, section 516, Audit findings, establishes reporting requirements for audit findings. Title 45 CFR, Section 98.66 – Availability of funds, states in part: (d) The following obligation and liquidation provisions apply to States and Territories: (1) Discretionary Fund allotments shall be obligated in the fiscal year in which funds are awarded or in the succeeding fiscal year. Unliquidated obligations as of the end of the succeeding fiscal year shall be liquidated within one year. (2) (i) Mandatory Funds for States requesting Matching Funds per § 98.55 shall be obligated in the fiscal year in which the funds are granted and are available until expended. (ii) Mandatory Funds for States that do not request Matching Funds are available until expended. (3) Both the Federal and non-Federal share of the Matching Fund shall be obligated in the fiscal year in which the funds are granted and liquidated no later than the end of the succeeding fiscal year. Title 45 CFR, Section 98.67 – Fiscal requirements, states: (a) Lead Agencies shall expend and account for CCDF funds in accordance with their own laws and procedures for expending and accounting for their own funds. (b) Unless otherwise specified in this part, contracts that entail the expenditure of CCDF funds shall comply with the laws and procedures generally applicable to expenditures by the contracting agency of its own funds. (c) Fiscal control and accounting procedures shall be sufficient to permit: (1) Preparation of reports required by the Secretary under this subpart and under subpart H; and (2) The tracking of funds to a level of expenditure adequate to establish that such funds have not been used in violation of the provisions of this part. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2023-062 The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with financial reporting requirements for the Child Care and Development Fund Cluster. Assistance Listing Number and Title: 93.575 Child Care and Development Block Grant 93.575 COVID-19 Child Care and Development Block Grant 93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund Federal Grantor Name: U.S. Department of Health and Human Service Federal Award/Contract Number: 2103WACCDF; 2103WACCDD; 2203WACCDF; 2203WACCDD; 2303WACCDF; 2303WACCDD; 2003WACCC3; 2103WACDC6; 2103WACSC6; 2103WACCC5 Pass-through Entity Name: None Pass-through Award/Contract Number: None Applicable Compliance Component: Reporting Known Questioned Cost Amount: None Prior Year Audit Finding: Yes, Finding 2022-044 Background The Department of Children, Youth, and Families administers the federal Child Care and Development Fund (CCDF) grants to help eligible working families pay for child care and fund improvements to child care quality. In fiscal year 2023, the Department spent about $547.2 million in federal funding. The Department is required to submit a quarterly ACF-696 financial report for each open grant. These reports contain information on expenditures for three CCDF funding sources: the Mandatory Fund, the Matching Fund, and the Discretionary Fund. The Department uses CCDF expenditures recorded in the state’s accounting system to compile and support the ACF-696 report. The U.S. Department of Health and Human Services (HHS), which oversees the CCDF program at the federal level, requires recipients to have accounting procedures that are sufficient for tracing grants to a level of expenditure adequate to show that they have been used in accordance with program requirements. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. In prior audits, we reported the Department did not have adequate internal controls over financial reporting requirements for the CCDF program. The prior finding numbers were 2022-044 and 2021-038. Description of Condition The Department did not have adequate internal controls over and did not comply with financial reporting requirements for the CCDF program. The Department’s accounting records must provide and support the financial information reported on ACF-696 reports. During the audit period, the Department’s grant management practice was to process expenditure transfers at the fund level without identifying which expenditures it transferred. Therefore, we could not rely on the data supporting the Department’s reported ACF-696 expenditures and could not test whether the reports were accurate and complete. This condition is also referenced in audit finding 2023-058. We consider these internal control deficiencies to be a material weakness, which led to material noncompliance. Cause of Condition The Department is required to maintain sufficient documentation for each payment it makes using federal dollars. The Department’s accounting practices prevent it from meeting this requirement. In fiscal year 2021, the Department informed our Office that it had implemented what management referred to as fund-level accounting. This consisted of making significant accounting adjustments between funding sources in its general ledger without identifying the underlying transactions in the payment system that supported them. This affected all populations of childcare expenditures for every month of the fiscal year. HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant. Effect of Condition By not complying with requirements in federal law to maintain adequate supporting documentation for expenditures, the Department created a condition that made it impossible for our Office to audit the CCDF program expenditures reported on the ACF-696 financial report. Recommendations We recommend the Department design and implement internal controls to ensure the ACF-696 report is supported with transaction-level data that is sufficient to comply with federal law and state rules. Department’s Response The Department has managed the CCDF program since 2019, prior to that it was managed by the Department of Social and Health Services and the Department of Early Learning. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF grants to eligible clients and allowable activities in compliance with 45 CFR 98.67. This process consists of making grant level adjustments between allowable grant sources to properly spend grant dollars within the allowable period of performance and ensure level of effort and matching requirements. The Department’s grant adjustments were processed based on eligible clients and allowable activities and did not include child-level data as required by SAO. The Department held an informal meeting on February 23, 2022, with HHS representative, the State Auditor’s Office and the Office of Financial Management. The intent was to obtain the grantor’s perspective in whether proper grant accounting required the use of child-level data. HHS stated they would not offer an opinion until they received the completed finding from the state. However, the Cause of Condition of finding 2021-033 stated, “HHS officials informed the Department that these accounting practices do not comply with federal law, but management said they believe they are compliant.” The Department does not agree with SAO’s interpretation of the meeting outcome. In the area of CCDF eligibility, for state fiscal year 2021, the SAO also issued finding 2021-035, with questioned cost of $32 and in state fiscal year 2022, finding 2022-008 (temporary number) with no questioned costs. There were no other findings or exit items in the area of eligibility determination or the cost allocation of funds. Given that eligibility or cost allocation is not an area of concern and transfers were processed between CCDF source of funds with the same eligibility requirements, the Department is confident CCDF funding was spent appropriately within federal regulations. The Department received a management decision letter dated October 3, 2023, from HHS for finding 2021-033 (2020-038) which states: “the ACF noted that the auditor raised concern about the Department’s accounting procedures and efforts made to trace expenditures at the transaction-level. As the basis for the finding, the auditor used CFRs (200.53, 200.303, 200.403, 200.410) that do not apply to CCDF. Federal regulations allow Lead Agencies to expend and account for CCDF funds in accordance with their own procedures.” In addition, ACF did not sustain the disallowance of questioned costs and stated: “Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” The management decision letter also conveyed the following determination by HHS for finding 2021-035, 2020-039 on eligibility compliance: “The ACF believes the corrective actions taken or planned, as stated above, should prevent recurrence of this finding in the future. In addition, we recognize the continuous progression of the State’s actions to fully resolve this finding as the number of error cases and the number of questioned costs have both significantly declined over the last 3 years. Therefore, the ACF will not pursue the questioned costs of $32 since the state has taken corrective actions that appear to have resulted in an amount of questioned costs that are immaterial.” The ACF recommended, “that the Department work with the auditors to determine an appropriate methodology that can be tested to ensure childcare payments comply with Federal regulations.” The Department met with ACF and SAO on November 8, 2023, to discuss the ACF decision at which time ACF upheld the above statements that the finding was not substantiated. The Department is committed to collaborating with SAO to determine an appropriate methodology that identifies a sampling unit that can be used to accurately test compliance. The SAO maintained that the program is not auditable without child-level data. The Department does not currently have the staff and resources to develop and maintain the business process redesign, as well as the information technology initiatives necessary to meet the level of assurance as identified by SAO. In response to the auditor’s recommendations, the Department has submitted a budget request for the 2024 supplemental budget. If the request is funded, it would allow adjustments to include child-level data. Auditor’s Remarks The level of documentation needed to support grant expenditures is not established by our Office, but in title 45 of the U.S. Code of Federal Regulations and the state’s grant award. During the February 2022 meeting with HHS that the Department referenced in its response, the grantor stated the specific federal law the Department’s accounting procedures were noncompliant with was 45 CFR 98.67. We agree with the HHS management decision that our references to 2 CFR 200.53, 200.303, 200.403 and 200.410 in the prior finding were not correct. However, HHS adopted these same requirements in 45 CFR 75.2, 75.303, 75.403 and 75.410, respectfully. These requirements were all in place during the audit period. The proper references are included in this finding. In its response, the Department references previous findings related to the eligibility compliance requirement as a basis for asserting federal funds were spent properly. The requirements to determine whether a client is eligible to receive subsidized child care are different than the requirements to ensure the payments for those services are allowable, fall within each award’s period of performance and adequately supported. Without adequate transactional level payment data, our Office is unable to perform tests to verify the Department met these requirements. In addition, we also are unable to verify whether the Department complied with matching, level of effort and earmarking requirements, or that required financial information reported to the federal government was accurate. These matters are referenced in separate findings in our report. We disagree with the Department’s description of the meeting held with HHS program staff on November 8, 2023. The Department states HHS “upheld the above statements that the finding was not substantiated.” This is not accurate. During this meeting, HHS representatives conveyed the same message that they did in the management decision issued October 3, 2023. The finding was partially substantiated because the questioned costs identified in the audit would not be disallowed. The management decision states: “The ACF partially sustains the finding and recommendation. The ACF agrees with the auditor that the Department should strengthen internal controls to ensure payments to child care providers are allowable and properly supported.” “The ACF does not sustain a disallowance for the questioned costs in the amount of $271,353,409 representing the entire amount of the CCDF grant award. Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” We are not aware of what procedures ACF performed to conclude expenditures reported by the Department for fiscal year 2022 were spent only for allowable activities, were for allowable costs and met federal cost principles. We questioned all expenditures because, in our judgment, they were unauditable. Lastly, when the Washington State Legislature approved the Department’s 2023-25 biennial budget, it specified: “Funding in this subsection must be expended with internal controls that provide child-level detail for all transactions.” We reaffirm our finding and hope additional resources from the Legislature, to get down to child-level detail for all transactions, will resolve the auditing problems existing at the Department. We will review the status of the Department’s corrective action during our next audit. Applicable Laws and Regulations 45 U.S. Code of Federal Regulations (CFR) Part 75, section 303, Internal Controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 45 CFR Part 75, section 516, Audit findings, establishes reporting requirements for audit findings. Title 45 CFR, Section 98.67 – Fiscal requirements, states: (a) Lead Agencies shall expend and account for CCDF funds in accordance with their own laws and procedures for expending and accounting for their own funds. (b) Unless otherwise specified in this part, contracts that entail the expenditure of CCDF funds shall comply with the laws and procedures generally applicable to expenditures by the contracting agency of its own funds. (c) Fiscal control and accounting procedures shall be sufficient to permit: (1) Preparation of reports required by the Secretary under this subpart and under subpart H; and (2) The tracking of funds to a level of expenditure adequate to establish that such funds have not been used in violation of the provisions of this part. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.403(e) requires that costs be determined in accordance with GAAP to be allowable under federal awards. Condition: A 30-month contract was fully paid and charged to the federal award while 6 months of the contract were incurred during the fiscal year. Cause: The prepaid contract was recorded as an expense in the general ledger. The reviewer did not consider the contract term for GAAP and compliance requirements. Effect or Potential Effect: Questioned costs may be disallowed and repayment made. Questioned Costs: $54,000; 24 months of the prepaid contract not incurred. Context: A sample of 30 disbursements totaling $275,477 was selected for testing from a population of 147 disbursements totaling $788,841. The testing found 2 disbursements related to the prepaid contract and were not in compliance. Repeat Finding: No. Recommendation: Transactions should be recorded in accordance with GAAP with a review and approval for financial reporting as well as for compliance with allowability requirements. Training on cost principles per the Uniform Guidance should be provided to the finance department and program managers. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is receiving training.
Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.403(e) requires that costs be determined in accordance with GAAP to be allowable under federal awards. Condition: A 30-month contract was fully paid and charged to the federal award while 6 months of the contract were incurred during the fiscal year. Cause: The prepaid contract was recorded as an expense in the general ledger. The reviewer did not consider the contract term for GAAP and compliance requirements. Effect or Potential Effect: Questioned costs may be disallowed and repayment made. Questioned Costs: $54,000; 24 months of the prepaid contract not incurred. Context: A sample of 30 disbursements totaling $275,477 was selected for testing from a population of 147 disbursements totaling $788,841. The testing found 2 disbursements related to the prepaid contract and were not in compliance. Repeat Finding: No. Recommendation: Transactions should be recorded in accordance with GAAP with a review and approval for financial reporting as well as for compliance with allowability requirements. Training on cost principles per the Uniform Guidance should be provided to the finance department and program managers. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is receiving training.
Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.403(e) requires that costs be determined in accordance with GAAP to be allowable under federal awards. Condition: A 30-month contract was fully paid and charged to the federal award while 6 months of the contract were incurred during the fiscal year. Cause: The prepaid contract was recorded as an expense in the general ledger. The reviewer did not consider the contract term for GAAP and compliance requirements. Effect or Potential Effect: Questioned costs may be disallowed and repayment made. Questioned Costs: $54,000; 24 months of the prepaid contract not incurred. Context: A sample of 30 disbursements totaling $275,477 was selected for testing from a population of 147 disbursements totaling $788,841. The testing found 2 disbursements related to the prepaid contract and were not in compliance. Repeat Finding: No. Recommendation: Transactions should be recorded in accordance with GAAP with a review and approval for financial reporting as well as for compliance with allowability requirements. Training on cost principles per the Uniform Guidance should be provided to the finance department and program managers. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is receiving training.
Finding: 2023-003 –Significant Deficiency in Internal Control over Compliance and Noncompliance – Allowable Costs/Cost Principles Identification of federal program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Criteria: For purposes of the federal government, 2 CFR Chapter II part 200 Subpart E §200.403 requires 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. Condition: Expenditures charged to the federal award was not consistent with supporting documentation. Cause: The Organizations controls in place did not operate effectively to prevent or detect the error. Effect or potential effect: The Organization is not in compliance with 2 CFR §200.403 Questioned Costs: None Context: For this program, a sample of forty expenditures were tested for allowable cost/cost principles. Of the forty samples tested, one of the expenditures did not have adequate documentation to support the amount charged to the federal award. Identification of Repeat Finding: Not applicable. Recommendations: Management should review and assess the effectiveness of internal controls to ensure that the amounts charged to the federal awards have adequate documentation.Views of Responsible Officials: Please refer to Corrective Action Plan.
2023-002 – Allowable Costs/Cost Principles Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S425D200045, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: S425D200045 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Other Matters Criteria or Specific Requirement: Per 2 CFR 200.303 and 2 CFR Part 200.403(f), the School should have controls in place to ensure compliance with Allowable Costs/Cost Principles requirements. Condition: During our testing of a sample of payroll transactions charged to the grant we noted there was no documentation of the review and approval for payroll transactions that were coded to the program and the time and effort documentation for it. Context: It was identified that while the school has some supporting documentation for amounts by employee coded to the grant, there was no further documentation with additional information of the review and approval for how those amounts were allocated to the grant. Questioned Costs: Unknown Cause: The School was unable to locate any specific documentation of reviews and approvals for the expenses charged to the program. Effect: The School could charge an unallowable cost to the grant. Repeat Finding: This is not a repeat finding. Recommendation: CLA recommends the School ensures it documents the underlying support for how allowable payroll expenditures were charged to the program along with approval of that determination. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding number: 2023-001 CFDA number: 93.959 CFDA title: Block Grants for Prevention and Treatment of Substance Abuse Criteria: Under the Uniform Guidance, specifically 2 CFR 200.403(g), charges to Federal awards must be documented and supported by a system of internal controls, including documentation of approval of expenses. Condition: Although the Organization was able to provide copies of invoices for the underlying expenses tested, evidence of formal approval for certain expenses was unavailable. Cause: The Organization does not have a system in place to formally document all invoice approvals. Possible effect: While the examined underlying expenses appear necessary and reasonable for the performance of the federal award, there is an elevated risk of unallowable expenses being billed to federal awards. Recommendation: Management should implement procedures for the approval of invoices, clearly outlining the roles and responsibilities of personnel and detailing appropriate documentation of approvals. Views of responsible officials: We agree with the finding. Management does obtain approval for all invoices; however, in certain instances, approval may be given verbally and not formally documented. We will review our current procedures for obtaining and documenting approval and update the procedures to ensure adequate evidence of approval is documented.
Federal Agency: Department of Education Cluster/Program: Special Education Cluster AL Number(s): 84.027 Award Year: 2023 Compliance Requirement: Period of Performance Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement 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)). Management of the School District is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal pro¬gram. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of per¬forming their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context There were several invoices for costs that occurred prior to the start of the School District’s fiscal year 2023 IDEA special education grant. Since these costs occurred outside of the authorized period of performance, they are not eligible to be charged to that grant. Cause The School District has not established adequate procedures to ensure costs charged to the grant are within the authorized period of performance. Effect or Potential Effect Due to the weakness in internal control noted above, there are known and questioned costs reported related to salaries and contracted services incurred prior to the period of performance and charged to the grant. Questioned Costs Known questioned costs reported are $49,883. Recommendation The School District should implement controls to ensure that no costs are incurred for a grant prior to the authorized period of performance. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Federal Agency: Department of Education Cluster/Program: Special Education Cluster AL Number(s): 84.027 Award Year: 2023 Compliance Requirement: Period of Performance Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement 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)). Management of the School District is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal pro¬gram. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of per¬forming their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context There were several invoices for costs that occurred prior to the start of the School District’s fiscal year 2023 IDEA special education grant. Since these costs occurred outside of the authorized period of performance, they are not eligible to be charged to that grant. Cause The School District has not established adequate procedures to ensure costs charged to the grant are within the authorized period of performance. Effect or Potential Effect Due to the weakness in internal control noted above, there are known and questioned costs reported related to salaries and contracted services incurred prior to the period of performance and charged to the grant. Questioned Costs Known questioned costs reported are $49,883. Recommendation The School District should implement controls to ensure that no costs are incurred for a grant prior to the authorized period of performance. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Federal Agency: Department of Education Cluster/Program: Special Education Cluster AL Number(s): 84.027 Award Year: 2023 Compliance Requirement: Period of Performance Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement 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)). Management of the School District is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal pro¬gram. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of per¬forming their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context There were several invoices for costs that occurred prior to the start of the School District’s fiscal year 2023 IDEA special education grant. Since these costs occurred outside of the authorized period of performance, they are not eligible to be charged to that grant. Cause The School District has not established adequate procedures to ensure costs charged to the grant are within the authorized period of performance. Effect or Potential Effect Due to the weakness in internal control noted above, there are known and questioned costs reported related to salaries and contracted services incurred prior to the period of performance and charged to the grant. Questioned Costs Known questioned costs reported are $49,883. Recommendation The School District should implement controls to ensure that no costs are incurred for a grant prior to the authorized period of performance. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Federal Agency: Department of Education Cluster/Program: Special Education Cluster AL Number(s): 84.027 Award Year: 2023 Compliance Requirement: Period of Performance Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement 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)). Management of the School District is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal pro¬gram. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of per¬forming their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context There were several invoices for costs that occurred prior to the start of the School District’s fiscal year 2023 IDEA special education grant. Since these costs occurred outside of the authorized period of performance, they are not eligible to be charged to that grant. Cause The School District has not established adequate procedures to ensure costs charged to the grant are within the authorized period of performance. Effect or Potential Effect Due to the weakness in internal control noted above, there are known and questioned costs reported related to salaries and contracted services incurred prior to the period of performance and charged to the grant. Questioned Costs Known questioned costs reported are $49,883. Recommendation The School District should implement controls to ensure that no costs are incurred for a grant prior to the authorized period of performance. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Federal Agency: Department of Education Cluster/Program: Special Education Cluster AL Number(s): 84.027 Award Year: 2023 Compliance Requirement: Period of Performance Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement 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)). Management of the School District is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal pro¬gram. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of per¬forming their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context There were several invoices for costs that occurred prior to the start of the School District’s fiscal year 2023 IDEA special education grant. Since these costs occurred outside of the authorized period of performance, they are not eligible to be charged to that grant. Cause The School District has not established adequate procedures to ensure costs charged to the grant are within the authorized period of performance. Effect or Potential Effect Due to the weakness in internal control noted above, there are known and questioned costs reported related to salaries and contracted services incurred prior to the period of performance and charged to the grant. Questioned Costs Known questioned costs reported are $49,883. Recommendation The School District should implement controls to ensure that no costs are incurred for a grant prior to the authorized period of performance. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Reference Number: 2023-003 Prior Year Finding: No Federal Agency: U.S. Department of Education Department: Portsmouth Public Schools (PPS) Federal Program: Special Education Cluster (IDEA) Assistance Listing: 84.027, 84.173 Federal Award Identification Number and Year: None, 2021 Pass-Through Entity: Commonwealth of Virginia Department of Education Pass-Through Award Number and Period: H027A200107 (7/1/20-9/30/22) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge 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)). Control – Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition PPS charged program costs to the grant after the period of performance period ended. We noted that an invoice for $176.05, for goods/services received in October 2022, wase charged to the federal grant ending September 2022. PPS did not obtain prior approval or an extension from the awarding agency before charging the grant. Context: One out of twenty-one samples selected for testing was charged to the grant after period of performance. Questioned costs: $176.05, represents the costs charged to the program after the period of performance. Cause: PPS did not consistently monitor the period of performance for a federal award to ensure that costs were only charged during the allowed period. Effect: PPS expensing of funds out of the period of performance may result in noncompliance and questioned costs from the grantor. Recommendation: We recommend that PPS enhance its procedures and internal controls to ensure that expenditures are not charged to federal awards during the period of performance. Views of responsible officials: Management agrees with the finding.
Reference Number: 2023-003 Prior Year Finding: No Federal Agency: U.S. Department of Education Department: Portsmouth Public Schools (PPS) Federal Program: Special Education Cluster (IDEA) Assistance Listing: 84.027, 84.173 Federal Award Identification Number and Year: None, 2021 Pass-Through Entity: Commonwealth of Virginia Department of Education Pass-Through Award Number and Period: H027A200107 (7/1/20-9/30/22) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge 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)). Control – Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition PPS charged program costs to the grant after the period of performance period ended. We noted that an invoice for $176.05, for goods/services received in October 2022, wase charged to the federal grant ending September 2022. PPS did not obtain prior approval or an extension from the awarding agency before charging the grant. Context: One out of twenty-one samples selected for testing was charged to the grant after period of performance. Questioned costs: $176.05, represents the costs charged to the program after the period of performance. Cause: PPS did not consistently monitor the period of performance for a federal award to ensure that costs were only charged during the allowed period. Effect: PPS expensing of funds out of the period of performance may result in noncompliance and questioned costs from the grantor. Recommendation: We recommend that PPS enhance its procedures and internal controls to ensure that expenditures are not charged to federal awards during the period of performance. Views of responsible officials: Management agrees with the finding.
Finding number: 2023-012 Federal agency: U.S. Department of Treasury Programs: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance listing #: 21.027 Award year: 2023 Compliance requirement: Allowable Costs Criteria According to 2 CFR 200.403 Factors affecting allowability of costs: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (g) Be adequately documented. See also §§ 200.300 through 200.309 of this part. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3). Condition The Federal Government requires that costs must be adequately documented and must be incurred during the approved budget period. During our testing, we noted the College failed to provide a copy of check or ACH payment information for 1 expenditure, out of a sample of 5. As a result, the College was unable to provide the proof of payment to support the expenditure is an allowable cost. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to keep the proof of payment to support the expenditure that was reimbursed from the federal award. Effect The invoice that was reimbursed from the federal award may not be an allowable cost. Questioned Costs $1,655 Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should implement internal control procedures to verify that reimbursement requests are only submitted for invoices that have been paid. View of Responsible Officials The College agrees with the finding.
2023-003 – Allowable Costs/Cost Principles Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Substance Use Disorder Residential Treatment for Pregnant and Postpartum Women Assistance listing number: 93.243 Award year: 9/30/2018 – 9/29/2023 Criteria: According to 2 CFR Part 200.403, to be allowable under federal awards, costs must be adequately documented, be necessary and reasonable for the performance of the federal award, and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Additionally, according to 2 CFR Part 200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and comply with established accounting policies and practices of the entity. Condition: Accurate and complete records to support disbursements were not maintained for the program. We specifically noted the following: • SFRC is currently allocating payroll costs to the program based on budget estimates. There is not a process in place to compare the budget estimates to actual time and effort to ensure that budget estimates are accurate. • For one month during fiscal year 2023, the amounts charged to the program were not supported by wages paid to the employee (used as the basis for the amount allocated to the program). • For two of six non-payroll disbursements tested, the amount allocated to the program did not agree to the amount paid to the vendor. • Indirect costs charged to the program were not allocated correctly based on SFRC’s approved indirect cost rate. Context: 15 of 15 payroll transactions tested were allocated to the program based on budget estimates. Two of six non-payroll disbursements did not agree with source documentation. Questioned Costs: $33,429 Cause: SFRC has not developed a process to compare the budget estimates to actual time and effort to ensure that budget estimates are accurate. There was not adequate review of reimbursement requests to ensure that payroll and non-payroll disbursements agree with source documentation. Indirect costs were not charged to the program using the approved indirect cost rate for fiscal year 2023. Effect: SFRC may not be able to demonstrate that costs charged to federal programs are allowable. Auditor’s Recommendation: SFRC should implement a process of comparing actual time and effort of employees to SFRC’s budget estimates at least bi-annually. Alternatively, SFRC could require employees to report their actual daily time on federal awards to ensure amounts charged are accurate and properly allocated. SFRC should implement a review process of reimbursement requests to ensure that disbursements agree with source documentation, and that indirect costs are charged to the program accurately. Management’s Response: Management implemented a process to evaluate time spent each month. That allocation is used to classify actual salary paid to particular federal awards on a pay period basis.
Criteria: CFR 200.403 states “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.” Condition: In testing, the Agency was not able to provide support for 2 of 80 expenditure transactions reviewed. Cause: The Agency has not implemented procedures, to the degree necessary, to ensure that support/source documentation is maintained and readily available for grant expenses. Effect: Expenses are not properly supported with documentation. The Agency was not able to provide support for 2 of 80 expenditure transactions reviewed. Questioned Costs: N/A Recommendation: We recommend that the Agency update record retention controls to improve retention processes. Views of Responsible Officials: Management agrees with this finding and their response is included in this corrective action plan.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.