Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Federal Agencies: Department of Health and Human Services Federal Assistance Listing Numbers: 93.110 Program: Maternal and Child Health Federal Consolidated Programs Pass-Through Entity Identifying Numbers: N/A Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.431 - Compensation - Fringe Benefits: ?The cost of fringe benefits in the form of employer contributions or expenses for social security; employee life, health, unemployment, and worker's compensation insurance (except as indicated in ? 200.447); pension plan costs (see paragraph (i) of this section); and other similar benefits are allowable, provided such benefits are granted under established written policies. Such benefits, must be allocated to Federal awards and all other activities in a manner consistent with the pattern of benefits attributable to the individuals or group(s) of employees whose salaries and wages are chargeable to such Federal awards and other activities, and charged as direct or indirect costs in accordance with the non-Federal entity's accounting practices.? Per 2 CFR Section 200.430 - Compensation ? Personnel Services: ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: a. The system for establishing the estimates produces reasonable approximations of the activity actually performed. b. Significant changes in the corresponding work activity (as defined by the non-Federal entity?s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and c. The non-Federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.? In addition, per 2 CFR Section 200.403 regarding all direct 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. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. (g) Be adequately documented.? Condition: We noted that Safe & Sound allocated fringe benefits during 2022 based on a flat percentage of salaries charged to the grant based on a methodology determined during the budget making process. The methodology was isolated to charges of fringe benefits. In addition, shared costs (e.g., insurance and occupancy) during 2022 were charged on a monthly basis as one twelfth of the total budgeted amount for the year. The methodology was isolated to certain shared costs. Safe & Sound does not have a process in place to true-up certain costs charged based on budget during interim periods to actual amounts. Context: Total fringe benefits charged to the grant were $38,534. Total shared costs charged to the grant were $16,536. Cause: Safe & Sound did not have policies and procedures in place to review and reconcile the budgeted amounts of fringe benefits or shared costs charged to the actual expenditures incurred. Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted totals are reasonable and reconcile to the actual time spent on the program, Safe & Sound could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement. Safe & Sound is entitled to under the terms of the grant. Questioned Costs: $55,070 Identification as a Repeat Finding: Not Applicable. Recommendation: We recommend that Safe & Sound implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR 200.430. In addition, we recommend training be provided to staff on requirements of their federal grants. Views of Responsible Officials: Management agrees with the finding. Management will implement policies and procedures to ensure a true up between budget and actual is completed and ensure all actuals are properly supported.
Federal Agencies: Department of Health and Human Services Federal Assistance Listing Numbers: 93.110 Program: Maternal and Child Health Federal Consolidated Programs Pass-Through Entity Identifying Numbers: N/A Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.414: ?In addition to the procedures outlined in the appendices in paragraph (e) of this section, any non-Federal entity that does not have a current negotiated (including provisional) rate, except for those non-Federal entities described in appendix VII to this part, paragraph D.1.b, may elect to charge a de minimis rate of 10% of modified total direct costs (MTDC) which may be used indefinitely. No documentation is required to justify the 10% de minimis indirect cost rate. As described in ? 200.403, costs must be consistently charged as either indirect or direct costs, but may not be double charged or inconsistently charged as both. If chosen, this methodology once elected must be used consistently for all Federal awards until such time as a non-Federal entity chooses to negotiate for a rate, which the non-Federal entity may apply to do at any time.? As defined by 2 CFR Section 200.1: ?Modified Total Direct Cost (MTDC) means all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward (regardless of the period of performance of the subawards under the award). MTDC excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000. Other items may only be excluded when necessary to avoid a serious inequity in the distribution of indirect costs, and with the approval of the cognizant agency for indirect costs.? Condition: We noted that the calculation for indirect costs utilized the incorrect base which was not the MTDC. Context: Safe & Sound utilizes the de minimis indirect rate of 10% of MTDC. The condition was identified in a recalculation of indirect costs based on MTDC for 2022. Cause: Safe & Sound did not have policies and procedures in place to ensure indirect cost rate is calculated based on the appropriate base, MTDC. Effect or Potential Effect: Without adequate controls in place to ensure indirect costs are calculated based on MTDC, Safe & Sound could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement Safe & Sound is entitled to under the terms of the grant. Questioned Costs: Below reporting threshold. Identification as a Repeat Finding: Not Applicable. Recommendation: We recommend that Safe & Sound implement policies and procedures to review indirect cost calculations based on MTDC and provide training to staff. Views of Responsible Officials: Management agrees with the finding. Management will implement policies and procedures to appropriately calculate indirect costs.
Finding 2022-006: Internal Controls over Compliance B. Allowable Costs/Cost Principles related to the Payroll Process U.S. DEPARTMENT OF JUSTICE Children Exposed to Violence ? Assistance Listing No. 16.818 Criteria: Controls over payroll processes should be in place to allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct misstatements in a timely manner. Per CFR Part 200.403, factors affecting allowability of costs, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity and be adequately documented in order to be allowable under federal awards. Condition: During 2022, there was a general lack of controls over payroll processes noted for direct payroll costs charged to the Children Exposed to Violence federal program: ? For one employee, the pay rate used to calculate payroll charged to the federal program for one pay period selected for testing did not match the authorized pay rate included in the employee?s human resources records. ? Timecards were not available for any employees for one pay period selected for testing. ? Payroll was not properly allocated to the federal program based on supporting employee timecards between July 10, 2022 and December 31, 2022. Cause: This condition was caused by a combination of a lack of staffs? physically present at the Youthprise office during the year, a lack of staff and oversight of finance department activities, and due to the turnover of finance staff during 2022, as discussed in finding 2022- 002 above. Additionally, during 2022 Youthprise switched payroll processing providers. The one pay period tested which lacked timecards occurred during the payroll provider transition. The improper allocation of time occurred after the new payroll processing provider transition was complete. Effect: By not having effective internal controls over payroll processes, there is a risk that misstatements and unallowable costs charged to federal programs could occur and not be detected in a timely manner. Context: A sample of four pay periods totaling $12,889 was selected for audit from a population of twenty six pay periods totaling $107,968. Although there was a lack of internal controls over the payroll process as noted above, Youthprise was able to substantiate that the total payroll costs charged to the program were allowable and that no overcharges to the federal program occurred. Our sample was a statistically valid sample. Questioned Costs: $0 Identification of Repeat Finding: Not a repeat finding. Recommendation: We recommend Youthprise develop and implement internal controls to ensure sufficient oversight is maintained over its payroll processes to prevent or detect and correct misstatements on a timely basis. Views of Responsible Officials and Corrective Action Plan: The discrepancies in payroll reporting were identified by Youthprise during 2023. Management discovered that reports downloaded from the third-party processor were not accurately coding salary based on timecard reports submitted by some of its employees. Youthprise is working with its Human Resources consultant, who is working with the 3rd party payroll processor, to correct the reporting issues going forward. Youthprise will review its internal controls going forward to ensure sufficient oversight is maintained over its payroll processes to prevent or detect and correct misstatements on a timely basis.
Criteria: 2CFR 200.403, Factors affecting allowability of costs, states that in order for a cost to be allowable under Federal awards it must be accorded consistent treatment. 2CFR 200.412 states that each item of cost for the same purpose must be treated consistently in like circumstances as either a direct or an indirect cost in order to avoid double-charging of Federal awards. Appendix IV to Part 200 4, Direct Allocation Method, all costs are treated as direct costs except general administration and general expenses. Under this method indirect costs consist exclusively of general administration and general expenses. 2CFR 200.425, Audit services, states the audit costs of auditing a non-federal entity that is exempted from having an audit conducted under the Single Audit Act and subpart F of this part because its expenditures under Federal awards are less than $750,000 during the non-Federal entity?s fiscal year are unallowable. 2CFR200.432, Conferences, defines allowable conferences as those necessary and reasonable for successful performance under the Federal award. Condition: A portion of the audit fee for the December 31, 2021 audit was charged as a direct expense ($423). The Council was not required to have a Single Audit for 2021, so this would not be considered allowable. A portion of the fees to send the finance director and a Board member to a conference ($750) were charged as a direct expense. Neither of these attendees were involved in the direct performance of the Federal program, so this would not be considered allowable. Costs for QuickBooks accounting software and payroll services, HR related software, and website costs ($4,047) were charged as direct costs. These are general administration expenses that should have been classified as indirect costs. Further, costs were not treated consistently within the accounting system. A portion of the audit costs, conference fees and software/computer costs were recorded as direct costs to the Federal program and a portion were recorded as indirect costs to other programs. The Organization did not have internal controls in place to meet the costs principles contained in the Uniform Guidance due to the issue discussed in Comment 2022-001. Cause: The Organization was not aware the grants received were Federal awards and they were not familiar with the cost principles contained in the Uniform Guidance. They were relying on the budget accepted by the Agency that passed them the awards. Effect: Since the 10% de minimis indirect cost rate was used, any unallowable costs that were reported as direct costs would cause the calculated indirect costs to be overstated. The grantor could request that any direct costs considered unallowable be repaid. Context: The unallowable costs noted were a minor portion of the direct costs charged to the Federal program. The program was charged approximately $463,000 of direct costs. Approximately 83% ($384,000) of the direct costs were wages, benefits and independent contractor fees for providers that worked directly for the Opiod STR program and direct rent for the program space. No exceptions we noted during our testing of these. The remaining 17% of the direct costs (approximately $79,000) were for a variety of expenses. We separated these items into 2 categories: recurring/annual charges allocated to the program of approximately $24,000 and other various costs. We tested the Organization?s allocation methodology for the identifiable recurring/annual costs. The results of this testing identified items that should have been classified as general administration indirect costs, as described above, which amounted to approximately $4,500. Testing was also done on the other various direct costs. There were 177 of these items totaling approximately $55,000. We tested a sample of 20 of these items. $750 of directly allocated costs for a conference were considered unallowable out of this testing. Questioned Costs: As a result of our testing, we concluded that the potentially unallowable costs and change in the indirect calculation would not be significantly different than the amounts discussed above and would not approach the $25,000 threshold for questioned costs. As a result, no costs have been questioned. Recommendation: We recommend that personnel involved in grant management and recordkeeping receive training on the Uniform Guidance cost principles and other pertinent Federal regulations. We recommend that a system and review process be implemented to insure that all costs are treated consistently and classified properly and that costs charged to Federal awards are appropriate. The Organization should follow the cost principles when designing budgets for future programs.
Assistance Listing Number, Federal Agency, and Program Name - 20.106, Federal Aviation Administration, Airport Improvement Program Federal Award Identification Number and Year - 3-26-0039-068-2022; 2022 Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The Uniform Guidance cost principles described in 2 CFR Part 200, Subpart E, apply to the Airport Improvement Program. Except as otherwise authorized by statute, costs must be determined except for state and local governments or as otherwise provided for in the Code of Federal Regulations (2 CFR 200.403). Condition - Unallowable costs incurred prior to the period of performance under the grant agreement were submitted and reimbursed by the granting agency. Additionally, these costs were initially included on the schedule of expenditures of federal awards. Questioned Costs - $139,625 Identification of How Questioned Costs Were Computed - The questioned costs were determined by totaling all invoices charged to the grant for costs incurred prior to the period of performance and not eligible for reimbursement. Context - The questioned costs of $139,625 charged to the grant related to the same project approved by the granting agency; however, these costs fell outside of the stipulated project period within the grant application and were designated to be covered by the Authority's local match requirement. Cause and Effect - Internal control procedures relative to the identification of federal expenditures to be charged to the grant did not operate effectively. This resulted in the unallowable costs charged to the grant and the Authority's schedule of expenditures of federal awards to be inaccurate prior to corrections made by management. Recommendation - We recommend that the Authority enhance review procedures prior to submission of grant reimbursements to ensure that costs were incurred in the period of performance under the grant. Views of Responsible Officials and Planned Corrective Actions - The personnel responsible for submitting reimbursement requests will review grant agreements with the personnel responsible for applying for the grants upon their award. Worksheets created for reimbursement and reporting will be reviewed against the grant schedules for accuracy.
Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In addition, per 2 CFR Section 200.403, ?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 allocablethereto under these principles. (b)Conform to any limitations or exclusions set forth in these principles or in the Federal awardas to types or amount of cost items. (c)Be consistent with policies and procedures that apply uniformly to both federally-financedand other activities of the non-Federal entity. (d)Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocatedto the Federal award as an indirect cost. (e)Be determined in accordance with generally accepted accounting principles (GAAP), except,for state and local governments and Indian tribes only, as otherwise provided for in this part. (f)Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. (g)Be adequately documented.? Condition ? In our examination of the program?s indirect cost charges, we noted that APS did not charge the appropriate indirect cost of $81,916 for the months of May through July 2022 to the program. Consequently, an adjustment was recorded to correct the SEFA. Cause ? Management did not adhere to their internal policies and procedures to ensure that all federal transactions are charged to the programs and that the SEFA is complete and accurate. Effect or potential effect ? The SEFA may not be fairly presented, in all material respects, in relation to the basic financial statements taken as a whole. In addition, the lack of adherence to the established internal controls policies and procedures can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Questioned Costs ? None. Context ? This is a condition identified per review of APS? compliance with specified requirements using a statistically valid sample. Recommendation ? We recommend that APS strengthen their policies and procedures to ensure the completeness and accuracy of the SEFA. Views of Responsible Officials - APS concurs with this finding. APS?s corrective action is described in the Management?s Corrective Action Plan included below.
Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In addition, per 2 CFR Section 200.403, ?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 allocablethereto under these principles. (b)Conform to any limitations or exclusions set forth in these principles or in the Federal awardas to types or amount of cost items. (c)Be consistent with policies and procedures that apply uniformly to both federally-financedand other activities of the non-Federal entity. (d)Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocatedto the Federal award as an indirect cost. (e)Be determined in accordance with generally accepted accounting principles (GAAP), except,for state and local governments and Indian tribes only, as otherwise provided for in this part. (f)Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. (g)Be adequately documented.? Condition ? In our examination of the program?s indirect cost charges, we noted that APS did not charge the appropriate indirect cost of $81,916 for the months of May through July 2022 to the program. Consequently, an adjustment was recorded to correct the SEFA. Cause ? Management did not adhere to their internal policies and procedures to ensure that all federal transactions are charged to the programs and that the SEFA is complete and accurate. Effect or potential effect ? The SEFA may not be fairly presented, in all material respects, in relation to the basic financial statements taken as a whole. In addition, the lack of adherence to the established internal controls policies and procedures can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Questioned Costs ? None. Context ? This is a condition identified per review of APS? compliance with specified requirements using a statistically valid sample. Recommendation ? We recommend that APS strengthen their policies and procedures to ensure the completeness and accuracy of the SEFA. Views of Responsible Officials - APS concurs with this finding. APS?s corrective action is described in the Management?s Corrective Action Plan included below.
Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In addition, per 2 CFR Section 200.403, ?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 allocablethereto under these principles. (b)Conform to any limitations or exclusions set forth in these principles or in the Federal awardas to types or amount of cost items. (c)Be consistent with policies and procedures that apply uniformly to both federally-financedand other activities of the non-Federal entity. (d)Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocatedto the Federal award as an indirect cost. (e)Be determined in accordance with generally accepted accounting principles (GAAP), except,for state and local governments and Indian tribes only, as otherwise provided for in this part. (f)Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. (g)Be adequately documented.? Condition ? In our examination of the program?s indirect cost charges, we noted that APS did not charge the appropriate indirect cost of $81,916 for the months of May through July 2022 to the program. Consequently, an adjustment was recorded to correct the SEFA. Cause ? Management did not adhere to their internal policies and procedures to ensure that all federal transactions are charged to the programs and that the SEFA is complete and accurate. Effect or potential effect ? The SEFA may not be fairly presented, in all material respects, in relation to the basic financial statements taken as a whole. In addition, the lack of adherence to the established internal controls policies and procedures can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Questioned Costs ? None. Context ? This is a condition identified per review of APS? compliance with specified requirements using a statistically valid sample. Recommendation ? We recommend that APS strengthen their policies and procedures to ensure the completeness and accuracy of the SEFA. Views of Responsible Officials - APS concurs with this finding. APS?s corrective action is described in the Management?s Corrective Action Plan included below.
Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In addition, per 2 CFR Section 200.403, ?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 allocablethereto under these principles. (b)Conform to any limitations or exclusions set forth in these principles or in the Federal awardas to types or amount of cost items. (c)Be consistent with policies and procedures that apply uniformly to both federally-financedand other activities of the non-Federal entity. (d)Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocatedto the Federal award as an indirect cost. (e)Be determined in accordance with generally accepted accounting principles (GAAP), except,for state and local governments and Indian tribes only, as otherwise provided for in this part. (f)Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. (g)Be adequately documented.? Condition ? In our examination of the program?s indirect cost charges, we noted that APS did not charge the appropriate indirect cost of $81,916 for the months of May through July 2022 to the program. Consequently, an adjustment was recorded to correct the SEFA. Cause ? Management did not adhere to their internal policies and procedures to ensure that all federal transactions are charged to the programs and that the SEFA is complete and accurate. Effect or potential effect ? The SEFA may not be fairly presented, in all material respects, in relation to the basic financial statements taken as a whole. In addition, the lack of adherence to the established internal controls policies and procedures can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Questioned Costs ? None. Context ? This is a condition identified per review of APS? compliance with specified requirements using a statistically valid sample. Recommendation ? We recommend that APS strengthen their policies and procedures to ensure the completeness and accuracy of the SEFA. Views of Responsible Officials - APS concurs with this finding. APS?s corrective action is described in the Management?s Corrective Action Plan included below.
Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In addition, per 2 CFR Section 200.403, ?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 allocablethereto under these principles. (b)Conform to any limitations or exclusions set forth in these principles or in the Federal awardas to types or amount of cost items. (c)Be consistent with policies and procedures that apply uniformly to both federally-financedand other activities of the non-Federal entity. (d)Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocatedto the Federal award as an indirect cost. (e)Be determined in accordance with generally accepted accounting principles (GAAP), except,for state and local governments and Indian tribes only, as otherwise provided for in this part. (f)Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. (g)Be adequately documented.? Condition ? In our examination of the program?s indirect cost charges, we noted that APS did not charge the appropriate indirect cost of $81,916 for the months of May through July 2022 to the program. Consequently, an adjustment was recorded to correct the SEFA. Cause ? Management did not adhere to their internal policies and procedures to ensure that all federal transactions are charged to the programs and that the SEFA is complete and accurate. Effect or potential effect ? The SEFA may not be fairly presented, in all material respects, in relation to the basic financial statements taken as a whole. In addition, the lack of adherence to the established internal controls policies and procedures can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Questioned Costs ? None. Context ? This is a condition identified per review of APS? compliance with specified requirements using a statistically valid sample. Recommendation ? We recommend that APS strengthen their policies and procedures to ensure the completeness and accuracy of the SEFA. Views of Responsible Officials - APS concurs with this finding. APS?s corrective action is described in the Management?s Corrective Action Plan included below.
Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In addition, per 2 CFR Section 200.403, ?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 allocablethereto under these principles. (b)Conform to any limitations or exclusions set forth in these principles or in the Federal awardas to types or amount of cost items. (c)Be consistent with policies and procedures that apply uniformly to both federally-financedand other activities of the non-Federal entity. (d)Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocatedto the Federal award as an indirect cost. (e)Be determined in accordance with generally accepted accounting principles (GAAP), except,for state and local governments and Indian tribes only, as otherwise provided for in this part. (f)Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. (g)Be adequately documented.? Condition ? In our examination of the program?s indirect cost charges, we noted that APS did not charge the appropriate indirect cost of $81,916 for the months of May through July 2022 to the program. Consequently, an adjustment was recorded to correct the SEFA. Cause ? Management did not adhere to their internal policies and procedures to ensure that all federal transactions are charged to the programs and that the SEFA is complete and accurate. Effect or potential effect ? The SEFA may not be fairly presented, in all material respects, in relation to the basic financial statements taken as a whole. In addition, the lack of adherence to the established internal controls policies and procedures can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Questioned Costs ? None. Context ? This is a condition identified per review of APS? compliance with specified requirements using a statistically valid sample. Recommendation ? We recommend that APS strengthen their policies and procedures to ensure the completeness and accuracy of the SEFA. Views of Responsible Officials - APS concurs with this finding. APS?s corrective action is described in the Management?s Corrective Action Plan included below.
Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: The Salvation Army of Dane County Award Period: 12/01/2021 - 04/30/2022 Criteria or Specific Requirement: According to 2 CFR section 200.403(h), a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Condition: YWCA charged costs incurred after the period of performance to the award. Four individually important items totaling $56,117 and a sample of ten charges totaling $10,952 were selected for testing from a population of 73 charges totaling $108,448. The testing found one charge totaling $2,964 that was incurred after the award period ended. Cause: YWCA did not properly design policies and procedures to ensure period of performance is timely reviewed and approved. In addition, YWCA experienced turnover in the CFO position, which is responsible for reviewing and approving period of performance.Effect or Potential Effect: Costs incurred before or after the period of performance may be disallowed. Repeat Finding: No. Recommendation: YWCA should establish written policies and procedures to provide for timely and appropriate review and approval for period of performance. Views of Responsible Officials: YWCA agrees with the finding and is establishing policies and procedures to provide for timely and appropriate review and approval of period of performance. This is expected to be completed by September 2023.
Finding 2022-002 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Differences were noted when comparing the summary to timecards. Within the sample of 45, we noted that 31 timecards did not have a documented review. From the sample, we noted that the pay advice form, which reflects pay rate changes, for 2 employees did not indicate signature by an approver and only indicated the requestor?s signature. The employees? new pay rate as indicated on the pay advice form was reflected in the payroll expenditure. Additionally, within the sample of 45, we noted 1 employee that did not have a pay advice form or contract to support the pay rate. We noted the following control items: ? 31 out of 45 timecards tested did not have documented review. ? 2 out of 45 employees tested did not have pay advice forms signed by both the requestor and reviewer. Only the requestor signed the form. ? 1 out of 45 employees tested did not have a pay advice form or other supporting documentation for the pay rate. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: The lack of documented timecard and pay rate approval were an oversight. Questioned Costs: None Recommendation: We recommend the Corporation maintain documented approval of all timecards and pay rate increases. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-002 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Differences were noted when comparing the summary to timecards. Within the sample of 45, we noted that 31 timecards did not have a documented review. From the sample, we noted that the pay advice form, which reflects pay rate changes, for 2 employees did not indicate signature by an approver and only indicated the requestor?s signature. The employees? new pay rate as indicated on the pay advice form was reflected in the payroll expenditure. Additionally, within the sample of 45, we noted 1 employee that did not have a pay advice form or contract to support the pay rate. We noted the following control items: ? 31 out of 45 timecards tested did not have documented review. ? 2 out of 45 employees tested did not have pay advice forms signed by both the requestor and reviewer. Only the requestor signed the form. ? 1 out of 45 employees tested did not have a pay advice form or other supporting documentation for the pay rate. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: The lack of documented timecard and pay rate approval were an oversight. Questioned Costs: None Recommendation: We recommend the Corporation maintain documented approval of all timecards and pay rate increases. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-002 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Differences were noted when comparing the summary to timecards. Within the sample of 45, we noted that 31 timecards did not have a documented review. From the sample, we noted that the pay advice form, which reflects pay rate changes, for 2 employees did not indicate signature by an approver and only indicated the requestor?s signature. The employees? new pay rate as indicated on the pay advice form was reflected in the payroll expenditure. Additionally, within the sample of 45, we noted 1 employee that did not have a pay advice form or contract to support the pay rate. We noted the following control items: ? 31 out of 45 timecards tested did not have documented review. ? 2 out of 45 employees tested did not have pay advice forms signed by both the requestor and reviewer. Only the requestor signed the form. ? 1 out of 45 employees tested did not have a pay advice form or other supporting documentation for the pay rate. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: The lack of documented timecard and pay rate approval were an oversight. Questioned Costs: None Recommendation: We recommend the Corporation maintain documented approval of all timecards and pay rate increases. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-002 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Differences were noted when comparing the summary to timecards. Within the sample of 45, we noted that 31 timecards did not have a documented review. From the sample, we noted that the pay advice form, which reflects pay rate changes, for 2 employees did not indicate signature by an approver and only indicated the requestor?s signature. The employees? new pay rate as indicated on the pay advice form was reflected in the payroll expenditure. Additionally, within the sample of 45, we noted 1 employee that did not have a pay advice form or contract to support the pay rate. We noted the following control items: ? 31 out of 45 timecards tested did not have documented review. ? 2 out of 45 employees tested did not have pay advice forms signed by both the requestor and reviewer. Only the requestor signed the form. ? 1 out of 45 employees tested did not have a pay advice form or other supporting documentation for the pay rate. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: The lack of documented timecard and pay rate approval were an oversight. Questioned Costs: None Recommendation: We recommend the Corporation maintain documented approval of all timecards and pay rate increases. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-002 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Differences were noted when comparing the summary to timecards. Within the sample of 45, we noted that 31 timecards did not have a documented review. From the sample, we noted that the pay advice form, which reflects pay rate changes, for 2 employees did not indicate signature by an approver and only indicated the requestor?s signature. The employees? new pay rate as indicated on the pay advice form was reflected in the payroll expenditure. Additionally, within the sample of 45, we noted 1 employee that did not have a pay advice form or contract to support the pay rate. We noted the following control items: ? 31 out of 45 timecards tested did not have documented review. ? 2 out of 45 employees tested did not have pay advice forms signed by both the requestor and reviewer. Only the requestor signed the form. ? 1 out of 45 employees tested did not have a pay advice form or other supporting documentation for the pay rate. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: The lack of documented timecard and pay rate approval were an oversight. Questioned Costs: None Recommendation: We recommend the Corporation maintain documented approval of all timecards and pay rate increases. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-002 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Differences were noted when comparing the summary to timecards. Within the sample of 45, we noted that 31 timecards did not have a documented review. From the sample, we noted that the pay advice form, which reflects pay rate changes, for 2 employees did not indicate signature by an approver and only indicated the requestor?s signature. The employees? new pay rate as indicated on the pay advice form was reflected in the payroll expenditure. Additionally, within the sample of 45, we noted 1 employee that did not have a pay advice form or contract to support the pay rate. We noted the following control items: ? 31 out of 45 timecards tested did not have documented review. ? 2 out of 45 employees tested did not have pay advice forms signed by both the requestor and reviewer. Only the requestor signed the form. ? 1 out of 45 employees tested did not have a pay advice form or other supporting documentation for the pay rate. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: The lack of documented timecard and pay rate approval were an oversight. Questioned Costs: None Recommendation: We recommend the Corporation maintain documented approval of all timecards and pay rate increases. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-002 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Differences were noted when comparing the summary to timecards. Within the sample of 45, we noted that 31 timecards did not have a documented review. From the sample, we noted that the pay advice form, which reflects pay rate changes, for 2 employees did not indicate signature by an approver and only indicated the requestor?s signature. The employees? new pay rate as indicated on the pay advice form was reflected in the payroll expenditure. Additionally, within the sample of 45, we noted 1 employee that did not have a pay advice form or contract to support the pay rate. We noted the following control items: ? 31 out of 45 timecards tested did not have documented review. ? 2 out of 45 employees tested did not have pay advice forms signed by both the requestor and reviewer. Only the requestor signed the form. ? 1 out of 45 employees tested did not have a pay advice form or other supporting documentation for the pay rate. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: The lack of documented timecard and pay rate approval were an oversight. Questioned Costs: None Recommendation: We recommend the Corporation maintain documented approval of all timecards and pay rate increases. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-002 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Differences were noted when comparing the summary to timecards. Within the sample of 45, we noted that 31 timecards did not have a documented review. From the sample, we noted that the pay advice form, which reflects pay rate changes, for 2 employees did not indicate signature by an approver and only indicated the requestor?s signature. The employees? new pay rate as indicated on the pay advice form was reflected in the payroll expenditure. Additionally, within the sample of 45, we noted 1 employee that did not have a pay advice form or contract to support the pay rate. We noted the following control items: ? 31 out of 45 timecards tested did not have documented review. ? 2 out of 45 employees tested did not have pay advice forms signed by both the requestor and reviewer. Only the requestor signed the form. ? 1 out of 45 employees tested did not have a pay advice form or other supporting documentation for the pay rate. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: The lack of documented timecard and pay rate approval were an oversight. Questioned Costs: None Recommendation: We recommend the Corporation maintain documented approval of all timecards and pay rate increases. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-002 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Differences were noted when comparing the summary to timecards. Within the sample of 45, we noted that 31 timecards did not have a documented review. From the sample, we noted that the pay advice form, which reflects pay rate changes, for 2 employees did not indicate signature by an approver and only indicated the requestor?s signature. The employees? new pay rate as indicated on the pay advice form was reflected in the payroll expenditure. Additionally, within the sample of 45, we noted 1 employee that did not have a pay advice form or contract to support the pay rate. We noted the following control items: ? 31 out of 45 timecards tested did not have documented review. ? 2 out of 45 employees tested did not have pay advice forms signed by both the requestor and reviewer. Only the requestor signed the form. ? 1 out of 45 employees tested did not have a pay advice form or other supporting documentation for the pay rate. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: The lack of documented timecard and pay rate approval were an oversight. Questioned Costs: None Recommendation: We recommend the Corporation maintain documented approval of all timecards and pay rate increases. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-002 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Differences were noted when comparing the summary to timecards. Within the sample of 45, we noted that 31 timecards did not have a documented review. From the sample, we noted that the pay advice form, which reflects pay rate changes, for 2 employees did not indicate signature by an approver and only indicated the requestor?s signature. The employees? new pay rate as indicated on the pay advice form was reflected in the payroll expenditure. Additionally, within the sample of 45, we noted 1 employee that did not have a pay advice form or contract to support the pay rate. We noted the following control items: ? 31 out of 45 timecards tested did not have documented review. ? 2 out of 45 employees tested did not have pay advice forms signed by both the requestor and reviewer. Only the requestor signed the form. ? 1 out of 45 employees tested did not have a pay advice form or other supporting documentation for the pay rate. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: The lack of documented timecard and pay rate approval were an oversight. Questioned Costs: None Recommendation: We recommend the Corporation maintain documented approval of all timecards and pay rate increases. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.
Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In addition, per 2 CFR Section 200.403, ?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 allocablethereto under these principles. (b)Conform to any limitations or exclusions set forth in these principles or in the Federal awardas to types or amount of cost items. (c)Be consistent with policies and procedures that apply uniformly to both federally-financedand other activities of the non-Federal entity. (d)Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocatedto the Federal award as an indirect cost. (e)Be determined in accordance with generally accepted accounting principles (GAAP), except,for state and local governments and Indian tribes only, as otherwise provided for in this part. (f)Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. (g)Be adequately documented.? Condition ? In our examination of the program?s indirect cost charges, we noted that APS did not charge the appropriate indirect cost of $81,916 for the months of May through July 2022 to the program. Consequently, an adjustment was recorded to correct the SEFA. Cause ? Management did not adhere to their internal policies and procedures to ensure that all federal transactions are charged to the programs and that the SEFA is complete and accurate. Effect or potential effect ? The SEFA may not be fairly presented, in all material respects, in relation to the basic financial statements taken as a whole. In addition, the lack of adherence to the established internal controls policies and procedures can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Questioned Costs ? None. Context ? This is a condition identified per review of APS? compliance with specified requirements using a statistically valid sample. Recommendation ? We recommend that APS strengthen their policies and procedures to ensure the completeness and accuracy of the SEFA. Views of Responsible Officials - APS concurs with this finding. APS?s corrective action is described in the Management?s Corrective Action Plan included below.
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: Documentation for certain expenses was unavailable or incomplete. Cause: Management currently lacks sufficient resources to locate all supporting documentation. The work from home environment has impacted existing processes and retention of information, along with turnover in the accounting department. Effect: Management was unable to fully substantiate $71,054 of $168,234 of nonpayroll items selected for testing. These are determined to be questioned costs. Context: We tested 40 haphazardly selected expense items. Of these, management was unable to locate complete documentation for four expenses, including two payments made and two journal entries to accrue expenses. Recommendation: Management should revise its transaction documentation system to allow for centralized and accessible storage of support for programmatic costs by all appropriate personnel who interact with external auditors, including local funding sources. For accrued items, management should retain journal entry documentation including invoices included within accrued amounts. Views of responsible officials: We agree with the finding. We are in the process of developing a formal contract management system and process that includes additional review and oversight. We are also in the process of hiring a grants and contracts compliance manager.
2022-002 - Emergency Solutions Grant - Assistance Listing No. 14.231 Significant Deficiency in Internal Control Over Compliance and Noncompliance – A. Activities Allowed or Unallowed and B. Allowable Costs/Cost Principles Criteria: 2 CFR 200.403(g) indicates costs must be adequately documented in order to be considered allowable. Condition and Context: During 2022, FSA maintained payroll records which included detailed timecards or time studies for employees who spent hours worked on the Emergency Solutions Grant (ESG). We selected 8 employees for testing during the audit and noted that 2 employees did not maintain detailed timecards or a time study and 3 employees worked less hours on ESG than what were claimed for reimbursement under the grant. Our sample was not considered to be a statistically valid sample. Cause and Effect: We noted a lack of internal controls surrounding the tracking of hours worked for ESG during 2022 which resulted in noncompliance. We tested 8 employees for a total of $14,431 of claimed payroll cost and calculated known questioned costs of $2,196 which resulted in likely questioned costs of $8,703 using an error rate of 15% over total payroll claimed for 2022 of $57,188. Total likely questioned costs were 2% of overall ESG expenditures for 2022. Recommendation: We recommend FSA implement procedures for all employees who have payroll claimed under federal programs to maintain detailed timecards or time studies to support hours worked under each federal program. Views of Responsible Officials and Planned Corrective Actions: Family Service Association of Howard County, Inc.’s (FSA) accounting department experienced significant turnover during 2022 which included the Director of Accounting leaving mid-year. Since the new Director of Accounting took on her role we have been actively working on ways to enhance our processes. Family Service Association of Howard County, Inc. (FSA) will implement procedures and maintain timecards and time studies for employees who have payroll claimed under the federal programs to be in compliance of federal grants beginning April 2024.
2022-002 - Emergency Solutions Grant - Assistance Listing No. 14.231 Significant Deficiency in Internal Control Over Compliance and Noncompliance – A. Activities Allowed or Unallowed and B. Allowable Costs/Cost Principles Criteria: 2 CFR 200.403(g) indicates costs must be adequately documented in order to be considered allowable. Condition and Context: During 2022, FSA maintained payroll records which included detailed timecards or time studies for employees who spent hours worked on the Emergency Solutions Grant (ESG). We selected 8 employees for testing during the audit and noted that 2 employees did not maintain detailed timecards or a time study and 3 employees worked less hours on ESG than what were claimed for reimbursement under the grant. Our sample was not considered to be a statistically valid sample. Cause and Effect: We noted a lack of internal controls surrounding the tracking of hours worked for ESG during 2022 which resulted in noncompliance. We tested 8 employees for a total of $14,431 of claimed payroll cost and calculated known questioned costs of $2,196 which resulted in likely questioned costs of $8,703 using an error rate of 15% over total payroll claimed for 2022 of $57,188. Total likely questioned costs were 2% of overall ESG expenditures for 2022. Recommendation: We recommend FSA implement procedures for all employees who have payroll claimed under federal programs to maintain detailed timecards or time studies to support hours worked under each federal program. Views of Responsible Officials and Planned Corrective Actions: Family Service Association of Howard County, Inc.’s (FSA) accounting department experienced significant turnover during 2022 which included the Director of Accounting leaving mid-year. Since the new Director of Accounting took on her role we have been actively working on ways to enhance our processes. Family Service Association of Howard County, Inc. (FSA) will implement procedures and maintain timecards and time studies for employees who have payroll claimed under the federal programs to be in compliance of federal grants beginning April 2024.
(2022-004) Allowable Costs and Procurement Federal Agency: U.S. Department of Treasury CFDA No.: 21.027 Federal Program: Coronavirus State and Local Fiscal Recovery Funds Federal Award Year: 2022 Control Category: Allowable Costs and Procurement, Suspension and Debarment Questioned Costs: $804.05 Condition The Center did not retain evidence of competitive bidding or evidence of verifying suspension and debarment for the two contracts selected for testing. Additionally, the Center did not retain invoice support and documentation of approval for two disbursements selected for testing. Criteria 2 CFR 200.403 Factors Affecting Allowability of Costs, states, in part that costs “be adequately documented”. 2 CFR 200.320 Methods of Procurement includes several required procurement procedures including competitive bidding and verification that vendors re not suspended or debarred from working with the federal government. Cause The Center did not retain evidence of bidding, suspension and debarment, or invoice documentation for certain purchases. Effect We are unable to determine if the costs are allowable in accordance with the Uniform Guidance. Management Response The Center will retain evidence of competitive bidding, unless an emergency or other situation precluding the delay of competitive bidding has arisen (in which case, the Center will retain the evidence and rationale justifying the sole source contract). The Center will retain verification of suspension and debarment for all potential contract service providers. The Center notes that one of the contracts selected for testing arose during an emergency situation (flooding). CFO will ensure that all invoices and supporting documentation are retained. ED and/or Director of Legal Services(depending on amount of expenditure, both may be required) will approve electronic payments inBill.com. Approval of expenses paid with paper checks will be indicated by signature of checks after reviewing accompanying support.
(2022-004) Allowable Costs and Procurement Federal Agency: U.S. Department of Treasury CFDA No.: 21.027 Federal Program: Coronavirus State and Local Fiscal Recovery Funds Federal Award Year: 2022 Control Category: Allowable Costs and Procurement, Suspension and Debarment Questioned Costs: $804.05 Condition The Center did not retain evidence of competitive bidding or evidence of verifying suspension and debarment for the two contracts selected for testing. Additionally, the Center did not retain invoice support and documentation of approval for two disbursements selected for testing. Criteria 2 CFR 200.403 Factors Affecting Allowability of Costs, states, in part that costs “be adequately documented”. 2 CFR 200.320 Methods of Procurement includes several required procurement procedures including competitive bidding and verification that vendors re not suspended or debarred from working with the federal government. Cause The Center did not retain evidence of bidding, suspension and debarment, or invoice documentation for certain purchases. Effect We are unable to determine if the costs are allowable in accordance with the Uniform Guidance. Management Response The Center will retain evidence of competitive bidding, unless an emergency or other situation precluding the delay of competitive bidding has arisen (in which case, the Center will retain the evidence and rationale justifying the sole source contract). The Center will retain verification of suspension and debarment for all potential contract service providers. The Center notes that one of the contracts selected for testing arose during an emergency situation (flooding). CFO will ensure that all invoices and supporting documentation are retained. ED and/or Director of Legal Services(depending on amount of expenditure, both may be required) will approve electronic payments inBill.com. Approval of expenses paid with paper checks will be indicated by signature of checks after reviewing accompanying support.
2022-006: Period of Performance – Material Weakness – Originated in 2019 Federal Program Information: Funding Agency: U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: H49MC00119-22-00 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2020-2024 Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR sections 200.308 200.309 and 200.403(h)), the Organization 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. Condition: The Organization lacked supporting documentation for certain non-payroll expenses and lacked evidence of review for certain non-payroll expenses. Due to lack of supporting documentation and evidence of approval for payment, certain transactions could not be verified. Of the sixty (60) transactions examined, eight (8) lacked supporting documentation and twenty five (25) lacked evidence of review, and approval for payment. Effect: Management possibly did not expend funds in accordance with the approved detailed line-item budget and grant agreement and possibly expended funds in the incorrect period of performance. Cause: Expenses including approved invoices and/or supporting documentation were not properly maintained in part due to several changes in personnel within the accounting area and overall limited number of personnel for certain functions and lack of board oversight. Questioned Costs: Known questioned costs of $980 and likely questioned costs of $5,791 for Healthy Start. Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all expenses include supporting documentation/invoice indicating period of performance.
2022-006: Period of Performance – Material Weakness – Originated in 2019 Federal Program Information: Funding Agency: U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: H49MC00119-22-00 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2020-2024 Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR sections 200.308 200.309 and 200.403(h)), the Organization 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. Condition: The Organization lacked supporting documentation for certain non-payroll expenses and lacked evidence of review for certain non-payroll expenses. Due to lack of supporting documentation and evidence of approval for payment, certain transactions could not be verified. Of the sixty (60) transactions examined, eight (8) lacked supporting documentation and twenty five (25) lacked evidence of review, and approval for payment. Effect: Management possibly did not expend funds in accordance with the approved detailed line-item budget and grant agreement and possibly expended funds in the incorrect period of performance. Cause: Expenses including approved invoices and/or supporting documentation were not properly maintained in part due to several changes in personnel within the accounting area and overall limited number of personnel for certain functions and lack of board oversight. Questioned Costs: Known questioned costs of $980 and likely questioned costs of $5,791 for Healthy Start. Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all expenses include supporting documentation/invoice indicating period of performance.
Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation. “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. b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b). g) Be adequately documented. See also §200.300 through §200.309. 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: National CASA/GAL allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that: For Court Appointed Special Advocates: • One of 60 transactions was partially charged in the incorrect fiscal period. • One of 60 transactions underlying supporting documentation was not retained. • 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs. • 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For the Juvenile Mentoring Program: • One of 60 transactions lacked documentation of all required reviews and approvals. • One of 60 transactions the incorrect allocation rate was utilized. • One of 60 transactions underlying supporting documentation was not retained. • 27 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations is appropriately maintained as required by §200.403. Views of Responsible Officials: Management concurs with the finding that procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.
Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation. “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. b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b). g) Be adequately documented. See also §200.300 through §200.309. 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: National CASA/GAL allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that: For Court Appointed Special Advocates: • One of 60 transactions was partially charged in the incorrect fiscal period. • One of 60 transactions underlying supporting documentation was not retained. • 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs. • 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For the Juvenile Mentoring Program: • One of 60 transactions lacked documentation of all required reviews and approvals. • One of 60 transactions the incorrect allocation rate was utilized. • One of 60 transactions underlying supporting documentation was not retained. • 27 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations is appropriately maintained as required by §200.403. Views of Responsible Officials: Management concurs with the finding that procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.
Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation. “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. b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b). g) Be adequately documented. See also §200.300 through §200.309. 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: National CASA/GAL allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that: For Court Appointed Special Advocates: • One of 60 transactions was partially charged in the incorrect fiscal period. • One of 60 transactions underlying supporting documentation was not retained. • 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs. • 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For the Juvenile Mentoring Program: • One of 60 transactions lacked documentation of all required reviews and approvals. • One of 60 transactions the incorrect allocation rate was utilized. • One of 60 transactions underlying supporting documentation was not retained. • 27 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations is appropriately maintained as required by §200.403. Views of Responsible Officials: Management concurs with the finding that procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.
Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation. “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. b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b). g) Be adequately documented. See also §200.300 through §200.309. 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: National CASA/GAL allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that: For Court Appointed Special Advocates: • One of 60 transactions was partially charged in the incorrect fiscal period. • One of 60 transactions underlying supporting documentation was not retained. • 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs. • 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For the Juvenile Mentoring Program: • One of 60 transactions lacked documentation of all required reviews and approvals. • One of 60 transactions the incorrect allocation rate was utilized. • One of 60 transactions underlying supporting documentation was not retained. • 27 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations is appropriately maintained as required by §200.403. Views of Responsible Officials: Management concurs with the finding that procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.
Fraudulent Checks Finding Number: 2022-006 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2022 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Pass-Through Entity: N/A Repeat Finding from Prior Audit? No Noncompliance, Material Weakness, and Questioned Cost 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR Part 200 Subpart E § 200.403 which provides that, except where otherwise authorized by statute, costs must meet certain general criteria in order to be allowable under Federal awards including being necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles and being adequately documented. State ex rel. McClure v. Hagerman, 155 Ohio St. 320 (1951), provides that expenditures made by a governmental unit should serve a public purpose. Typically, the determination of what constitutes a “proper public purpose” rests with the judgment of the governmental entity, unless such determination is arbitrary or unreasonable. Even if a purchase is reasonable, Ohio Attorney General Opinion 82006 indicates that it must be memorialized by a duly enacted ordinance or resolution and may have a prospective effect only. Auditor of State Bulletin 2003-005 Expenditure of Public Funds/Proper Public Purpose states, in part, the Auditor of State’s Office will only question expenditures where the legislative determination of a public purpose is manifestly arbitrary and incorrect. Due to lack of proper internal controls and fraud by the previous Executive Director, expenditures totaling $324,624 were posted to the Housing Voucher Cluster in 2022. These expenditures were not related to the Housing Voucher Cluster as they pertained to fraud. There was no valid support for the expenditures. As such, the entire $324,624 is considered a questioned cost. These costs were also not for proper public purposes. The Board and Authority management should implement proper internal controls to ensure proper segregation of duties to help prevent and deter fraud.
Fraudulent Checks Finding Number: 2022-006 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2022 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Pass-Through Entity: N/A Repeat Finding from Prior Audit? No Noncompliance, Material Weakness, and Questioned Cost 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR Part 200 Subpart E § 200.403 which provides that, except where otherwise authorized by statute, costs must meet certain general criteria in order to be allowable under Federal awards including being necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles and being adequately documented. State ex rel. McClure v. Hagerman, 155 Ohio St. 320 (1951), provides that expenditures made by a governmental unit should serve a public purpose. Typically, the determination of what constitutes a “proper public purpose” rests with the judgment of the governmental entity, unless such determination is arbitrary or unreasonable. Even if a purchase is reasonable, Ohio Attorney General Opinion 82006 indicates that it must be memorialized by a duly enacted ordinance or resolution and may have a prospective effect only. Auditor of State Bulletin 2003-005 Expenditure of Public Funds/Proper Public Purpose states, in part, the Auditor of State’s Office will only question expenditures where the legislative determination of a public purpose is manifestly arbitrary and incorrect. Due to lack of proper internal controls and fraud by the previous Executive Director, expenditures totaling $324,624 were posted to the Housing Voucher Cluster in 2022. These expenditures were not related to the Housing Voucher Cluster as they pertained to fraud. There was no valid support for the expenditures. As such, the entire $324,624 is considered a questioned cost. These costs were also not for proper public purposes. The Board and Authority management should implement proper internal controls to ensure proper segregation of duties to help prevent and deter fraud.
Criteria or specific requirement: 2 CFR 200.403(b) states that costs must "Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items". Per the Federal award (contract 2018-51300-28430, PTEIN C0535A-A), there was no specific allowability for “Fees”, and the budget indicated $0 allocated to “Fees”. 2 CFR 200.303(a) requires nonfederal entities receiving Federal awards to "Establish and maintain internal controls 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." 2 CFR 200.430(i)(1) states that "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Condition: (10.307) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 4 out of 17 samples tested. In addition, for 1 sample, the Organization charged unallowable costs (bank fees) to the major program. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 26 samples tested, resulting in wages being charged erroneously between programs. (10.311) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 5 out of 14 samples tested. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 21 samples tested, resulting in wages being charged erroneously between programs. During testing of indirect costs, it was noted that direct costs used to calculate the applied indirect cost rate were not supported by underlying documentation of costs incurred. Questioned costs: None Context: (10.307) For testing of general disbursements, a sample of 17 was made from a population of 113 disbursement transactions. Of the 17 sampled, 4 did not include documentary evidence of review and approval of the disbursement. In addition, 1 sample was found to be out of compliance with the provisions for 2 CFR 200.403(b). For testing of payroll, a sample of 26 was made from a population of 168 unique employee paychecks. Of the 26 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. (10.311) For testing of general disbursements, a sample of 14 was made from a population of 90 disbursement transactions. Of the 14 sampled, 5 did not include documentary evidence of review and approval of the disbursement. For testing of payroll, a sample of 21 was made from a population of 139 unique employee paychecks. Of the 21 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. For testing of indirect costs, a sample of 6 was made from a population of 21 monthly reimbursement invoices. Of the 6 sampled, 3 did not include sufficient documentation to support the direct costs used to apply the indirect cost rate. Cause: The Organization does not have adequate controls around the documentation of the supervisor review and approval process. Supervisory review and approvals are currently being communicated verbally. In addition, inadequate documentation is retained to document the time and effort of employee time spent on grants and the total direct costs that should be considered when applying the indirect cost rate. Effect: Without adequate records retained, the Organization is at risk of noncompliance with Federal programs and grant regulations, which could result in penalties or repayment obligations. Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, the Organization could incorrectly charge expenditures to the Federal program, report fraudulent expenditures, or not request appropriate reimbursement that the Organization is entitled to under the terms of the grant. Repeat Finding: No Recommendation: CLA recommends for the Organization to evaluate its current policies and procedures to implement an additional layer of review, and to formally document such review and approval procedures for all transactions affecting federal funds (i.e. approval of general expenditures, approval of timesheets, approval of indirect cost allocations). In addition, the Organization should emphasize the importance of detailed reviewed timesheets, including a second level review by the Finance Manager to ensure the accuracy and documentation of time and effort billed to each Federal program. Views of responsible officials: Management agrees with the finding.
Criteria or specific requirement: 2 CFR 200.403(b) states that costs must "Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items". Per the Federal award (contract 2018-51300-28430, PTEIN C0535A-A), there was no specific allowability for “Fees”, and the budget indicated $0 allocated to “Fees”. 2 CFR 200.303(a) requires nonfederal entities receiving Federal awards to "Establish and maintain internal controls 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." 2 CFR 200.430(i)(1) states that "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Condition: (10.307) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 4 out of 17 samples tested. In addition, for 1 sample, the Organization charged unallowable costs (bank fees) to the major program. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 26 samples tested, resulting in wages being charged erroneously between programs. (10.311) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 5 out of 14 samples tested. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 21 samples tested, resulting in wages being charged erroneously between programs. During testing of indirect costs, it was noted that direct costs used to calculate the applied indirect cost rate were not supported by underlying documentation of costs incurred. Questioned costs: None Context: (10.307) For testing of general disbursements, a sample of 17 was made from a population of 113 disbursement transactions. Of the 17 sampled, 4 did not include documentary evidence of review and approval of the disbursement. In addition, 1 sample was found to be out of compliance with the provisions for 2 CFR 200.403(b). For testing of payroll, a sample of 26 was made from a population of 168 unique employee paychecks. Of the 26 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. (10.311) For testing of general disbursements, a sample of 14 was made from a population of 90 disbursement transactions. Of the 14 sampled, 5 did not include documentary evidence of review and approval of the disbursement. For testing of payroll, a sample of 21 was made from a population of 139 unique employee paychecks. Of the 21 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. For testing of indirect costs, a sample of 6 was made from a population of 21 monthly reimbursement invoices. Of the 6 sampled, 3 did not include sufficient documentation to support the direct costs used to apply the indirect cost rate. Cause: The Organization does not have adequate controls around the documentation of the supervisor review and approval process. Supervisory review and approvals are currently being communicated verbally. In addition, inadequate documentation is retained to document the time and effort of employee time spent on grants and the total direct costs that should be considered when applying the indirect cost rate. Effect: Without adequate records retained, the Organization is at risk of noncompliance with Federal programs and grant regulations, which could result in penalties or repayment obligations. Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, the Organization could incorrectly charge expenditures to the Federal program, report fraudulent expenditures, or not request appropriate reimbursement that the Organization is entitled to under the terms of the grant. Repeat Finding: No Recommendation: CLA recommends for the Organization to evaluate its current policies and procedures to implement an additional layer of review, and to formally document such review and approval procedures for all transactions affecting federal funds (i.e. approval of general expenditures, approval of timesheets, approval of indirect cost allocations). In addition, the Organization should emphasize the importance of detailed reviewed timesheets, including a second level review by the Finance Manager to ensure the accuracy and documentation of time and effort billed to each Federal program. Views of responsible officials: Management agrees with the finding.
Criteria or specific requirement: 2 CFR 200.403(b) states that costs must "Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items". Per the Federal award (contract 2018-51300-28430, PTEIN C0535A-A), there was no specific allowability for “Fees”, and the budget indicated $0 allocated to “Fees”. 2 CFR 200.303(a) requires nonfederal entities receiving Federal awards to "Establish and maintain internal controls 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." 2 CFR 200.430(i)(1) states that "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Condition: (10.307) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 4 out of 17 samples tested. In addition, for 1 sample, the Organization charged unallowable costs (bank fees) to the major program. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 26 samples tested, resulting in wages being charged erroneously between programs. (10.311) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 5 out of 14 samples tested. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 21 samples tested, resulting in wages being charged erroneously between programs. During testing of indirect costs, it was noted that direct costs used to calculate the applied indirect cost rate were not supported by underlying documentation of costs incurred. Questioned costs: None Context: (10.307) For testing of general disbursements, a sample of 17 was made from a population of 113 disbursement transactions. Of the 17 sampled, 4 did not include documentary evidence of review and approval of the disbursement. In addition, 1 sample was found to be out of compliance with the provisions for 2 CFR 200.403(b). For testing of payroll, a sample of 26 was made from a population of 168 unique employee paychecks. Of the 26 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. (10.311) For testing of general disbursements, a sample of 14 was made from a population of 90 disbursement transactions. Of the 14 sampled, 5 did not include documentary evidence of review and approval of the disbursement. For testing of payroll, a sample of 21 was made from a population of 139 unique employee paychecks. Of the 21 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. For testing of indirect costs, a sample of 6 was made from a population of 21 monthly reimbursement invoices. Of the 6 sampled, 3 did not include sufficient documentation to support the direct costs used to apply the indirect cost rate. Cause: The Organization does not have adequate controls around the documentation of the supervisor review and approval process. Supervisory review and approvals are currently being communicated verbally. In addition, inadequate documentation is retained to document the time and effort of employee time spent on grants and the total direct costs that should be considered when applying the indirect cost rate. Effect: Without adequate records retained, the Organization is at risk of noncompliance with Federal programs and grant regulations, which could result in penalties or repayment obligations. Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, the Organization could incorrectly charge expenditures to the Federal program, report fraudulent expenditures, or not request appropriate reimbursement that the Organization is entitled to under the terms of the grant. Repeat Finding: No Recommendation: CLA recommends for the Organization to evaluate its current policies and procedures to implement an additional layer of review, and to formally document such review and approval procedures for all transactions affecting federal funds (i.e. approval of general expenditures, approval of timesheets, approval of indirect cost allocations). In addition, the Organization should emphasize the importance of detailed reviewed timesheets, including a second level review by the Finance Manager to ensure the accuracy and documentation of time and effort billed to each Federal program. Views of responsible officials: Management agrees with the finding.
Criteria or specific requirement: 2 CFR 200.403(b) states that costs must "Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items". Per the Federal award (contract 2018-51300-28430, PTEIN C0535A-A), there was no specific allowability for “Fees”, and the budget indicated $0 allocated to “Fees”. 2 CFR 200.303(a) requires nonfederal entities receiving Federal awards to "Establish and maintain internal controls 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." 2 CFR 200.430(i)(1) states that "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Condition: (10.307) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 4 out of 17 samples tested. In addition, for 1 sample, the Organization charged unallowable costs (bank fees) to the major program. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 26 samples tested, resulting in wages being charged erroneously between programs. (10.311) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 5 out of 14 samples tested. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 21 samples tested, resulting in wages being charged erroneously between programs. During testing of indirect costs, it was noted that direct costs used to calculate the applied indirect cost rate were not supported by underlying documentation of costs incurred. Questioned costs: None Context: (10.307) For testing of general disbursements, a sample of 17 was made from a population of 113 disbursement transactions. Of the 17 sampled, 4 did not include documentary evidence of review and approval of the disbursement. In addition, 1 sample was found to be out of compliance with the provisions for 2 CFR 200.403(b). For testing of payroll, a sample of 26 was made from a population of 168 unique employee paychecks. Of the 26 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. (10.311) For testing of general disbursements, a sample of 14 was made from a population of 90 disbursement transactions. Of the 14 sampled, 5 did not include documentary evidence of review and approval of the disbursement. For testing of payroll, a sample of 21 was made from a population of 139 unique employee paychecks. Of the 21 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. For testing of indirect costs, a sample of 6 was made from a population of 21 monthly reimbursement invoices. Of the 6 sampled, 3 did not include sufficient documentation to support the direct costs used to apply the indirect cost rate. Cause: The Organization does not have adequate controls around the documentation of the supervisor review and approval process. Supervisory review and approvals are currently being communicated verbally. In addition, inadequate documentation is retained to document the time and effort of employee time spent on grants and the total direct costs that should be considered when applying the indirect cost rate. Effect: Without adequate records retained, the Organization is at risk of noncompliance with Federal programs and grant regulations, which could result in penalties or repayment obligations. Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, the Organization could incorrectly charge expenditures to the Federal program, report fraudulent expenditures, or not request appropriate reimbursement that the Organization is entitled to under the terms of the grant. Repeat Finding: No Recommendation: CLA recommends for the Organization to evaluate its current policies and procedures to implement an additional layer of review, and to formally document such review and approval procedures for all transactions affecting federal funds (i.e. approval of general expenditures, approval of timesheets, approval of indirect cost allocations). In addition, the Organization should emphasize the importance of detailed reviewed timesheets, including a second level review by the Finance Manager to ensure the accuracy and documentation of time and effort billed to each Federal program. Views of responsible officials: Management agrees with the finding.
FINDING 2022-002 Subject: Child Support Enforcement - Allowable Costs/Cost Principles Federal Agency: Department of Health and Human Services Federal Program: Child Support Enforcement Assistance Listings Number: 93.563 Federal Award Number and Year (or Other Identifying Number): FY2022 Pass-Through Entity: Indiana Department of Child Services Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Noncompliance Condition and Context Indirect costs are expenses that are incurred by other County offices, which indirectly benefit the County Title IV-D offices. Indirect expenses are allocated to the County Title IV-D offices through an indirect Cost Allocation Plan (CAP) which is submitted to the Department of Child Services' Child Support Bureau. Indirect costs charged are based on two-year prior expenditures; therefore, indirect costs charged in 2022 were based on expenditures from 2020. A sample of 25 expenditures, totaling $27,077, from the department cost pools from the CAP were selected for testing. For 1 of the 25 expenditures examined, the County was unable to provide the contract; therefore, we were unable to verify if the correct rate for the contract payment was charged. For an additional 2 contracts requested, the contract could not be provided at the initial time of request. The contracts were provided nine months later at which time we verified the contract payment charged. In addition, the County did not have written procedures for determining the allowability of costs in accordance with Subpart E of 2 CFR 200. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "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. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items . . . (g) Be adequately documented. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (7) Written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the Federal award." Cause A proper system of internal controls over child support enforcement expenditures was not designed by management of the County. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the County's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, expenses within the cost application plan could not be verified as accurate. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County establish a proper system of internal controls and develop policies and procedures to ensure that costs included within the cost allocation plan have adequate supporting documentation to support the amount paid. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. Auditor's Response Sufficient, appropriate audit evidence in regard to supplement not supplant was determined to not have been obtained at the initial time of audit. As such, additional audit procedures were performed after the report date of September 29, 2023. The missing contracts were a part of the original report which was discussed and communicated to management on September 29, 2023. Contracts were not provided in September, nor was there a disagreement with this portion of the finding in the original corrective action plan provided by management. Documentation provided in June 2024 was unsolicited but was reviewed, and the issue noted in the finding was updated accordingly. While we agree two of the three contracts could be reviewed and verified once provided in June 2024, the third contract is still in question as noted in the finding.
FINDING 2022-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Allowable Costs/Cost Principles Federal Agency: Department of Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY 2022 Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context Allowable costs are based on the premise that a recipient is responsible for the effective administration of the federal award, application of sound management practices, and administration of federal funds in a manner consistent with the program objectives and terms and conditions of the awards. State and Local Fiscal Recovery Funds (SLFRF) recipients must implement internal controls and effective monitoring to ensure compliance with the cost principles. Costs were charged to the SLFRF award in two ways. Either directly, as an expense to the fund at the time of initial posting, or indirectly via a journal entry after the initial time of posting. Costs charged directly at the time of initial posting were reviewed and approved by an individual that had knowledge of the activity. Costs charged to the SLFRF award indirectly via a journal entry were completed by one employee with no review process in place to ensure the journal entry posted was allowable, accurate, and timely. Due to the lack of effective internal controls over direct payroll postings, 2 deviations out of 13 payroll transactions tested were not supported due to the City incorrectly calculating the firefighter overtime wages. The deviations noted were for the pay periods ending March 27, 2022, and July 3, 2022. This time frame was covered in an audit conducted by the Department of Labor (DOL). The audit conducted by the DOL was over the City's payroll pertaining to firefighter and paramedic overtime wages. The audit covered the period of March 8, 2020 to October 29, 2022, and concluded that the City underpaid 172 firefighters/paramedics due to incorrectly calculating the overtime wages for the audit period covered. Based on the audit conducted by the DOL, we tested two employees' payrolls from November 4, 2022 through December 30, 2022, which consisted of 10 additional transactions, to determine if the City had corrected the calculations after the audit period that was covered by the DOL audit. This testing identified that the City had not corrected the calculation issue for the overtime wages for these two employees which resulted in 9 additional deviations of noncompliance. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 24 CITY OF GARY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "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. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Cause A proper system of internal controls over payroll transactions was not effective to ensure that the City correctly calculated firefighter wages that were paid from the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds grant. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the City's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As such, costs paid from the SLFRF funds for overtime pay to firefighters and paramedics was not adequately documented. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the City. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the City design and implement a proper system of internal controls, including policies and procedures to ensure that the City's payroll is calculated properly based on the Fair Labor Standards Act (FLSA) requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2022-002 – INTERNAL CONTROLS OVER COMPLIANCE – ALLOWABLE COSTS/COST PRINCIPLES Material Weakness U.S. Department of Housing and Urban Development CFDA #: 14.871/14.879 – Housing Voucher Cluster CRITERIA 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. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non- Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal Award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this Part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (2 CFR Chapter 1 Part 200 § 200.403) CONDITION As disclosed in Finding 2022-001, the Authority lacked controls over the expenditure and recording of materials and supplies. As such, it is unknown whether or not these expenditures were appropriately charged to the Housing Voucher Program. CAUSE As disclosed in Finding 2022-001, the Authority did not establish an effective control environment or effective control activities over financial reporting or compliance. EFFECT Expenses may have been inappropriately charged to the Housing Voucher Cluster. QUESTIONED COSTS None identified. CONTEXT We reviewed the Authority’s internal controls over compliance with federal awards. REPEAT FINDING Repeat of finding 2021-002 RECOMMENDATION We recommend the Authority’s management take an active role in reviewing their policies and monitoring the Authority’s compliance with those policies. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2022-002 – INTERNAL CONTROLS OVER COMPLIANCE – ALLOWABLE COSTS/COST PRINCIPLES Material Weakness U.S. Department of Housing and Urban Development CFDA #: 14.871/14.879 – Housing Voucher Cluster CRITERIA 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. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non- Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal Award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this Part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (2 CFR Chapter 1 Part 200 § 200.403) CONDITION As disclosed in Finding 2022-001, the Authority lacked controls over the expenditure and recording of materials and supplies. As such, it is unknown whether or not these expenditures were appropriately charged to the Housing Voucher Program. CAUSE As disclosed in Finding 2022-001, the Authority did not establish an effective control environment or effective control activities over financial reporting or compliance. EFFECT Expenses may have been inappropriately charged to the Housing Voucher Cluster. QUESTIONED COSTS None identified. CONTEXT We reviewed the Authority’s internal controls over compliance with federal awards. REPEAT FINDING Repeat of finding 2021-002 RECOMMENDATION We recommend the Authority’s management take an active role in reviewing their policies and monitoring the Authority’s compliance with those policies. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.