2023-005 – Department of the Interior Federal Program Name: Natural Resource Stewardship - Pass-Through Agency: N/A Assistance Listing Number: 15.944 Federal Award Identification Year: 2023 Award Period: 10/01/2022 – 09/30/2023 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria: 2 CFR 200.414(c) – Federal awards recipients must negotiate an indirect cost rate with the cognizant agency for indirect costs, which is typically the federal agency that provides the most funding to the recipient. 2 CFR 200.403(d) – The negotiated rate must be applied consistently across all federal awards to ensure uniformity in cost allocation. 2 CFR 200.302(b)(3) – Recipients must maintain adequate documentation to support the indirect costs charged to federal awards, ensuring compliance with the cost principles outlined in the regulation Condition: For all invoices submitted to the grantor including those that included indirect cost rate calculations, there was no documented review and approval of the submission by management. Condition: Known: $94,287 Likely: $94,287 Context: Internal controls need to be formally documented as well as have support and authorization. With no authorization or proof that the internal control was completed, we cannot rely on the controls. Effect: Not having internal controls formalized and documented can lead to higher risk of noncompliance and misreporting. Cause: Internal controls are not formalized or documented Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that CIES modifies its internal control policies for general review and approval of the reporting requirements set forth by the criteria listed above. Management’s Views: See separate corrective action plan.
Noncompliance and Significant Deficiency in Internal Controls over Compliance for Subrecipient Monitoring Identification data: U.S. Department of Health and Human Services (HHS) – Mental and Behavioral Health Education and Training Grants, Assistance Listing No. 93.732, Agreement Identifying No. M0142518. Criteria: Title 2 CFR §200.332 describes subrecipient monitoring requirements for pass-through entities, which include the requirement that pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes but is not limited to: • Subrecipient name (which must match the name associated with its unique entity identifier); • Subrecipient's unique entity identifier; • Federal Award Identification Number (FAIN); • Subaward Period of Performance Start and End Date; • Subaward Budget Period Start and End Date; • Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; • Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; • Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); • Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; • Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; • Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. • All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; • Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; • A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and • Appropriate terms and conditions concerning closeout of the subaward. Condition: The Organization did not have a process of generating a subaward agreement that was in compliance with the criteria listed above. Cause: A breakdown in the Organization’s internal controls over subrecipient monitoring did not allow the Organization to fully meet the subrecipient monitoring requirements under the program. Effect or potential effect: The control deficiency is a significant deficiency that prevented the Organization from fully complying with the subrecipient monitoring requirements of the program. Identification of a Repeat Finding: New finding. Recommendation: The Organization should review its system of internal control over subrecipient monitoring to determine improvements that can be made to ensure the Organization has agreements that meet the required criteria identified above. Views of Responsible Officials: The Organization misunderstood the directions given by the Grants Management Specialist in this instance. The Organization has reviewed the requirements of Compliance for Subrecipient Monitoring and has controls in place to ensure those requirements are followed.
2023-002 Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Listing Number: 21.027 Federal Award Identification Number and Year: 22GOV0019AA, 2023 Pass-Through Agency: State of Connecticut Office of Workforce Strategy Pass-Through Number: SLFRP0128 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Organization must comply with indirect cost rate guidance set out at 2 CFR section 200.414 within Uniform Guidance. Condition: The Organization did not comply with indirect cost rate guidance set out at 2 CFR section 200.414 within Uniform Guidance. Questioned costs: $28,026 Context: The Organization did not comply with indirect cost rate guidance set out at 2 CFR section 200.414 within Uniform Guidance. Cause: Management was unaware of the requirement to use the actual base costs incurred multiplied by the 10% deminimis cost rate. Instead, they recorded the indirect costs monthly using an allocation of 1/12 of the indirect costs per the budget. Effect: There is a risk that indirect costs are not calculated correctly per the actual base costs incurred. Repeat Finding: No Recommendation: We recommend that the Organization review and follow the indirect cost rate guidance set out at 2 CFR section 200.414 within Uniform Guidance. Views of Responsible Officials: There is no disagreement with the audit finding.
Assistance Listing Number, Federal Agency, and Program Name - U.S. Department of Labor H-1B Job Training Grants (ALN 17.268) and WIA/WIOA Pilots, Demonstrations, and Research Projects Strengthening Community Colleges Training Grants (ALN 17.261). Federal Award Identification Number and Year - HG-35916-21-60-A-26 and MI-35900-21-60-A-26. Pass-through Entity - None. Finding Type - Significant deficiency. Repeat Finding - No. Criteria - A passthrough entity must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass through entity; (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of Federal awarding agency, pass through entity, and contact information for awarding official of the Pass through entity; (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. (2 CFR 200.332(a)). In addition, 2 CFR 200.332(d) states grantees are required to "Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition - The College had the following issues noted: (1) It did not include items (1)(ii) subrecipient's unique unique entity identifier and (1)(xi) Name of federal awarding agency, passthrough entity or contact information within their subrecipient agreement; (2) It was not monitoring the subrecipient budgets and performance plans to ensure objectives were met; and (3) It was not monitoring financial expenditures that were below planned thresholds. Questioned Costs - None. Context - There were 5 subrecipients for grant #17.268 and 6 subrecipients for grant #17.671. There was approval and review of expenditures submitted by all subrecipients on a timely basis. In addition, each subrecipient is required to complete and submit a quarterly narrative performance report which the College uses to prepare the quarterly narrative performance report submitted to the granting agency. Cause and Effect - The College did not have a system in place to monitor actual performance and financial measures against the planned activity as outlined in the subrecipient and grant agreements. The College was also not documenting the results of site visits of the subrecipients. Recommendation - The College should implement controls to have subrecipients track and report perfornance and financial for planned versus actual reporting on a monthly or quarterly basis. In addition, the College should complete a written report summarizing the results of each onsite visit to its subrecipients as required under Uniform Guidance. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The College has implemented a new Grants Administration Guide which covered initial risk assessment, subrecipient determination, subaward agreements, monitoring subrecipients and subrecipient reimbursements. In addition, the College has developed monthly metric reports for planned vs. actual outcomes which is to be completed by each subrecipient. The College has also scheduled formal site visits with each subrecipient to cover Financial status, metric verification, narrative overview and participant records and evaluation. A tool has been developed to summarize each site visit with recommendations. A written report will be provided to the subrecipients after each site visit.
Assistance Listing Number, Federal Agency, and Program Name - U.S. Department of Labor H-1B Job Training Grants (ALN 17.268) and WIA/WIOA Pilots, Demonstrations, and Research Projects Strengthening Community Colleges Training Grants (ALN 17.261). Federal Award Identification Number and Year - HG-35916-21-60-A-26 and MI-35900-21-60-A-26. Pass-through Entity - None. Finding Type - Significant deficiency. Repeat Finding - No. Criteria - A passthrough entity must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass through entity; (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of Federal awarding agency, pass through entity, and contact information for awarding official of the Pass through entity; (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. (2 CFR 200.332(a)). In addition, 2 CFR 200.332(d) states grantees are required to "Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition - The College had the following issues noted: (1) It did not include items (1)(ii) subrecipient's unique unique entity identifier and (1)(xi) Name of federal awarding agency, passthrough entity or contact information within their subrecipient agreement; (2) It was not monitoring the subrecipient budgets and performance plans to ensure objectives were met; and (3) It was not monitoring financial expenditures that were below planned thresholds. Questioned Costs - None. Context - There were 5 subrecipients for grant #17.268 and 6 subrecipients for grant #17.671. There was approval and review of expenditures submitted by all subrecipients on a timely basis. In addition, each subrecipient is required to complete and submit a quarterly narrative performance report which the College uses to prepare the quarterly narrative performance report submitted to the granting agency. Cause and Effect - The College did not have a system in place to monitor actual performance and financial measures against the planned activity as outlined in the subrecipient and grant agreements. The College was also not documenting the results of site visits of the subrecipients. Recommendation - The College should implement controls to have subrecipients track and report perfornance and financial for planned versus actual reporting on a monthly or quarterly basis. In addition, the College should complete a written report summarizing the results of each onsite visit to its subrecipients as required under Uniform Guidance. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The College has implemented a new Grants Administration Guide which covered initial risk assessment, subrecipient determination, subaward agreements, monitoring subrecipients and subrecipient reimbursements. In addition, the College has developed monthly metric reports for planned vs. actual outcomes which is to be completed by each subrecipient. The College has also scheduled formal site visits with each subrecipient to cover Financial status, metric verification, narrative overview and participant records and evaluation. A tool has been developed to summarize each site visit with recommendations. A written report will be provided to the subrecipients after each site visit.
FINDING 2023-002 Subject: COVID-19 - Education Stabilization Fund - Subrecipient Monitoring Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U210013 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, material noncompliance related to the COVID-19 - Education Stabilization Fund (ESF) funds passed through to subrecipients. The School Corporation received and passed through to subrecipients $420,500 of ESF funds. The School Corporation is to clearly identify the award and applicable requirements to the subrecipients, evaluate the risk of noncompliance related to the subrecipients to determine appropriate monitoring of the subaward, and monitor the activities of the subrecipients to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. The School Corporation did not enter into an agreement with the subrecipients. As such there is no agreement between the School Corporation and the subrecipients that clearly identifies the award as a subaward or includes all the required data elements. In addition, the School Corporation did not have any policies or procedures in place to evaluate the subrecipients' risk of noncompliance or to monitor the activity of the subrecipients. Per inquiry of the School Corporation, it was determined an evaluation of the risk of noncompliance for the subrecipients was not completed, nor did the subrecipients' files support any such evaluation. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.332 states: "All pass-through entities must: INDIANA STATE BOARD OF ACCOUNTS 18 WEST LAFAYETTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and include the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward notification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification. (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the passthrough entity; (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; INDIANA STATE BOARD OF ACCOUNTS 19 WEST LAFAYETTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (4) (i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: (A) The negotiated indirect cost rate between the pass-through entity and the subrecipient; which can be based on a prior negotiated rate between a different PTE and the same subrecipient. If basing the rate on a previously negotiated rate, the passthrough entity is not required to collect information justifying this rate, but may elect to do so; (B) The de minimis indirect cost rate. (ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. Subrecipients can elect to use the cost allocation method to account for indirect costs in accordance with § 200.405(d). (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. . . . (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in § 200.208. INDIANA STATE BOARD OF ACCOUNTS 20 WEST LAFAYETTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on programrelated matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in § 200.425. (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. INDIANA STATE BOARD OF ACCOUNTS 21 WEST LAFAYETTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (h) Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation'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, the School Corporation did not properly evaluate the subrecipients risk of noncompliance or adequately monitor the subrecipients. 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 School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls, including segregation of duties, to evaluate the subrecipients risk of noncompliance and adequately monitor the subrecipients. Additionally, policies and procedures should be implemented to ensure appropriate reviews, approvals, and oversight are taking place, as needed, to evaluate and monitor its subrecipients. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Type of Finding: Significant Deficiency in Internal Control over Compliance Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: DA-202201-00320-2022, DA-251-2022, DA-230-2022 Pass-Through Agency: King County Regional Homelessness Authority Pass-Through Number(s): DA-202201-00320, DA-251, DA-230 Award Period: January 1, 2022, to December 31, 2022, January 1, 2022, to December 31, 2022, January 1, 2022, to December 31, 2022 Criteria or specific requirement: 2 CFR 200.303(a) states that a non-federal entity must "Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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)". In addition, 2 CFR 200.414(f) states that "...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". Condition: During testing of indirect costs, 3 of the 11 contracts tested exceeded the 10% de minimis indirect cost rate elected by the organization. Questioned costs: ALN Contract Known Questioned Costs Likely Questioned Costs 21.027 DA-202201-00320 $5,554 None 21.027 DA-251 $22,994 None 21.027 DA-230 $463 None Context: CLA tested the entire population (11 contracts) for indirect costs charged to the major program. Of the contracts tested, 3 were found to be out of compliance with the provisions for 2 CFR 200.303(a) and 2 CFR 200.414(f). Indirect costs exceeding the 10% de minimis cost rate elected by CCS totaled $29,011. Cause: Due to the high volume of client assistance in these programs, there can be several general ledger reclassifications in each month. This is because clients may be eligible for a specific funding source or contract that differs from the original coding. This can lead to multiple general ledgers being sent between the accounting department and the program compliance teams. At times there has been a lack of communication to confirm the general ledger is finalized with indirect at 10%. Program managers will accidentally invoice before the adjustment. Effect: Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, CCS could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that CCS is entitled to under the terms of the grant. Inadequate allocation of indirect costs to federal programs may result in noncompliance with grant regulations, which could result in penalties or repayment obligations. Repeat Finding: No. Recommendation: CLA recommends that emphasis be placed during the billing process to ensure that no more than the 10% de minimis cost rate is charged each month. Views of responsible officials: There is no disagreement with the audit finding.
Type of Finding: Significant Deficiency in Internal Control over Compliance Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: DA-202201-00320-2022, DA-251-2022, DA-230-2022 Pass-Through Agency: King County Regional Homelessness Authority Pass-Through Number(s): DA-202201-00320, DA-251, DA-230 Award Period: January 1, 2022, to December 31, 2022, January 1, 2022, to December 31, 2022, January 1, 2022, to December 31, 2022 Criteria or specific requirement: 2 CFR 200.303(a) states that a non-federal entity must "Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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)". In addition, 2 CFR 200.414(f) states that "...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". Condition: During testing of indirect costs, 3 of the 11 contracts tested exceeded the 10% de minimis indirect cost rate elected by the organization. Questioned costs: ALN Contract Known Questioned Costs Likely Questioned Costs 21.027 DA-202201-00320 $5,554 None 21.027 DA-251 $22,994 None 21.027 DA-230 $463 None Context: CLA tested the entire population (11 contracts) for indirect costs charged to the major program. Of the contracts tested, 3 were found to be out of compliance with the provisions for 2 CFR 200.303(a) and 2 CFR 200.414(f). Indirect costs exceeding the 10% de minimis cost rate elected by CCS totaled $29,011. Cause: Due to the high volume of client assistance in these programs, there can be several general ledger reclassifications in each month. This is because clients may be eligible for a specific funding source or contract that differs from the original coding. This can lead to multiple general ledgers being sent between the accounting department and the program compliance teams. At times there has been a lack of communication to confirm the general ledger is finalized with indirect at 10%. Program managers will accidentally invoice before the adjustment. Effect: Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, CCS could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that CCS is entitled to under the terms of the grant. Inadequate allocation of indirect costs to federal programs may result in noncompliance with grant regulations, which could result in penalties or repayment obligations. Repeat Finding: No. Recommendation: CLA recommends that emphasis be placed during the billing process to ensure that no more than the 10% de minimis cost rate is charged each month. Views of responsible officials: There is no disagreement with the audit finding.
Type of Finding: Significant Deficiency in Internal Control over Compliance Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: DA-202201-00320-2022, DA-251-2022, DA-230-2022 Pass-Through Agency: King County Regional Homelessness Authority Pass-Through Number(s): DA-202201-00320, DA-251, DA-230 Award Period: January 1, 2022, to December 31, 2022, January 1, 2022, to December 31, 2022, January 1, 2022, to December 31, 2022 Criteria or specific requirement: 2 CFR 200.303(a) states that a non-federal entity must "Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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)". In addition, 2 CFR 200.414(f) states that "...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". Condition: During testing of indirect costs, 3 of the 11 contracts tested exceeded the 10% de minimis indirect cost rate elected by the organization. Questioned costs: ALN Contract Known Questioned Costs Likely Questioned Costs 21.027 DA-202201-00320 $5,554 None 21.027 DA-251 $22,994 None 21.027 DA-230 $463 None Context: CLA tested the entire population (11 contracts) for indirect costs charged to the major program. Of the contracts tested, 3 were found to be out of compliance with the provisions for 2 CFR 200.303(a) and 2 CFR 200.414(f). Indirect costs exceeding the 10% de minimis cost rate elected by CCS totaled $29,011. Cause: Due to the high volume of client assistance in these programs, there can be several general ledger reclassifications in each month. This is because clients may be eligible for a specific funding source or contract that differs from the original coding. This can lead to multiple general ledgers being sent between the accounting department and the program compliance teams. At times there has been a lack of communication to confirm the general ledger is finalized with indirect at 10%. Program managers will accidentally invoice before the adjustment. Effect: Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, CCS could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that CCS is entitled to under the terms of the grant. Inadequate allocation of indirect costs to federal programs may result in noncompliance with grant regulations, which could result in penalties or repayment obligations. Repeat Finding: No. Recommendation: CLA recommends that emphasis be placed during the billing process to ensure that no more than the 10% de minimis cost rate is charged each month. Views of responsible officials: There is no disagreement with the audit finding.
Federal Program Information: Transition Program for Students with Intellectual Disabilities into Higher Education Grant (ALN: 84.407A). Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): The auditee must prepare a schedule of expenditures of Federal awards (“SEFA”) for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with § 200.502. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available. For a cluster of programs also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total Federal awards expended for loan or loan guarantee programs in the schedule. (6) Include notes that describe that significant accounting policies used in preparing the schedule, and note whether or not the auditee elected to use the 10% de minimis cost rate as covered in § 200.414 (2 CFR section 200.510(b)). Condition: For certain Federal grant programs presented on the SEFA, the total amount provided to subrecipients during the year was not included. Cause: Administrative oversight with respect to SEFA preparation. Effect or Potential Effect: The University was not in compliance with SEFA presentation and disclosure requirements. Questioned Costs: None. Context: The University did not properly present and disclose approximately $162,000 of funds passed to subrecipients under the Transition Programs for Students with Intellectual Disabilities into Higher Education grant (ALN 84.407A) on the SEFA for the year ended June 30, 2023. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that the SEFA has been prepared in accordance with the required guidelines and that it contains all minimum required elements that must be presented and disclosed, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University Finance department has updated their policies and procedures to ensure that the SEFA is being prepared in accordance with required guidelines. We will work closely with our grants department to ensure all required elements are properly identified and disclosed.
Reference Number: 2023-009 Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Pass-Through Entity: N/A Federal Award Number and Year: Fiscal Year 2022-23 Name of Department: County Executive Office Internal Services Department Department of Consumer Business Affairs Department of Aging Category of Finding: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance; Instance of Noncompliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) § 200.332, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i.) Subrecipient name (which must match the name associated with its unique entity identifier); (ii.) Subrecipient's unique entity identifier; (iii.) Federal Award Identification Number (FAIN); (iv.) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (v.) Subaward Period of Performance Start and End Date; (vi.) Subaward Budget Period Start and End Date; (vii.) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii.) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix.) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x.) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi.) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii.) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii.) Identification of whether the award is R&D; and (xiv.) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Condition During our audit of the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program, we selected twenty-three (23) subrecipients with active contracts with the County during FY 2022-23. • One (1) contract administered by the Internal Services Department (ISD) did not include one or more of the required elements defined in 2 CFR § 200.332 (a)(1) in the subrecipients’ agreements. • One (1) contract administered by the Department of Consumer Affairs (DCBA) did not include one or more of the required elements defined in 2 CFR § 200.332(a)(1) in the subrecipients’ agreements. • For four (4) contracts administered by the Aging Department (AD), the AD did not perform subrecipient monitoring related to the CSLFRF program during FY 2022-23. Cause Due to the urgency to implement the CSLFRF program, the Notice of Federal Subaward Information was not completed and provided to the subrecipient for two (2) contracts. The AD was not aware of the requirement to conduct subrecipient monitoring related to the CSLFR program and did not perform subrecipient monitoring of four (4) contracts. Effect Failure to provide all the required subaward information may result in subrecipients incorrectly reporting on federal pass-through awards in their Single Audit reports. Failure to document monitoring results in noncompliance with the subrecipient monitoring requirements 2 CFR § 200.332. Questioned Costs Questioned costs were not determinable. Context Of the twenty-three (23) subrecipients selected for testing, which totaled $71,323,434, from a population of 124 subrecipients with expenditures totaling $90,592,053: • The departments did not communicate all of the required subaward data elements for two (2) subrecipients with expenditures totaling $7,305,087. • The AD did not perform subrecipient monitoring for four (4) subrecipients with expenditures totaling $8,542,012. The sample was not a statistically valid sample. Recommendation We recommend the County perform the following: 1. Remind departments that the Notice of Federal Subaward Information is a required attachment for all subrecipient agreements. In addition, subaward contract templates should be reviewed and revised to include placeholders for required information 2 CFR § 200.332(a)(1). 2. For existing subrecipients that were not provided the required elements, provide a letter or amended agreement to include all the required elements of 2 CFR § 200.332(a)(1). 3. Maintain sufficient records of monitoring subrecipients in accordance with subrecipient monitoring requirements.
Finding Reference Number: 2023-005 NH Department of Justice NH Department of Health and Human Services NH Department of Environmental Services NH Department of Business and Economic Affairs COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing #21.027) Federal Award Numbers: SLFRP0145 Federal Award Year: 2021 U.S. Department of Treasury Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-008 Statistically Valid Sample: No Criteria A pass-through entity must: 1. Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a); 2. Evaluate each subrecipient’s risk of noncompliance for the purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 300.332(b)); 3. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorization purposes, complies with the terms and conditions of the subaward 4. Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. Condition As part of the Coronavirus State and Local Fiscal Recovery Funds program, the State of New Hampshire (the State) entered into grant agreements with local entities to support allowable activities under the federal program. During the year ended June 30, 2022, the State passed through $73,337,682 to subrecipients. As part of our testwork over the subrecipient monitoring process, we identified the following breakdown of internal controls: A. As part of our testwork over subrecipient monitoring, we selected a sample of 49 items from the listing of subrecipients provided by the State that reconciled to the amount reported on the Schedule of Expenditures of Federal Awards. Of the 49 items selected for testwork, 6 items were contracts and were not subrecipient agreements. As such, we were unable to determine the completeness and accuracy of the subrecipient population. As a result of our audit, the State identified that this error resulted in the amount reported on the Schedule of Expenditures of Federal Awards as pass-through expenditures to be overstated by $7,261,684. The State has corrected the Schedule of Expenditures of Federal Awards so that the amount reported is accurate. B. The State communicates award information to subrecipients through the approved grant agreement. For 19 of the 43 remaining subrecipients selected for testwork, the State did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated: a. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414) was not communicated for 19 of the 43 remaining subrecipients selected for testwork. b. Identification of whether the award is R&D was not communicated for 17 of the remaining 43 subrecipients selected for testwork. C. As part of our testwork over during the award monitoring, it was identified that subrecipient monitoring activities include the review and approval of invoices submitted for reimbursement from the subrecipient. During our testwork over the invoice review we identified the following: a. For 6 of the remaining 43 subrecipients selected for testwork, we were unable to obtain the invoices paid by the State to verify that they were reviewed and approved. While the invoices were not provided to us, we noted that other monitoring procedures were performed for 4 of the 6 subrecipients. b. For 10 of the remaining 43 subrecipients selected for testwork, while we were able to obtain the invoices paid by the State, we were unable to properly identify who the appropriate reviewer was for the invoice to ensure that the individual who approved the invoice had the appropriate knowledge and competency to perform the review process. As a result, we were unable to verify if the invoice was appropriately reviewed. While we were unable to verify this, we noted that other monitoring procedures were performed for 9 of the 10 subrecipients. D. As part of our testwork over during the award monitoring, for 9 of the 43 remaining subrecipients selected for testwork, no documentation was provided to support that during the award monitoring procedures had been performed during the audit period. As such, we could not verify that appropriate monitoring procedures were performed as outlined by the subrecipient’s risk assessment. E. As part of our testwork over the review of Uniform Guidance Reports, we identified the following: a. For 6 of the remaining 43 subrecipients selected for testwork, the State provided the subrecipients Uniform Guidance report, however there was no evidence that the reports were reviewed to determine if a management decision letter needed to be issued. As part of our audit, we reviewed the 6 uniform guidance reports and did not identify any findings that would have required to be followed up on by the State. b. For 7 of the remaining 43 subrecipients selected for testwork, the subrecipient’s uniform guidance report was not provided. We reviewed the FAC to determine if a report was submitted during the audit period and identified that all 7 subrecipients had submitted a uniform guidance report. Of the 7 subrecipients, 1 report contained findings reported within Section III of the report. There was no evidence provided that the State had issued a management decision related to this subrecipient. Cause The cause of the condition found is primarily due to insufficient internal controls and procedures to ensure that award identification information is communicated, that appropriate during the award monitoring is performed based on the risk assessments and that all subrecipients are reviewed to determine if a uniform guidance audit was issued regardless of amount awarded to the subrecipient. Given the nature of this program, several Departments within the State entered into subrecipient grants resulting in a decentralized process. Not all Departments within the State are experienced with subrecipient relationships and may not have had developed policies to comply with subrecipient monitoring requirements. Finally, the State does not have sufficient internal controls in place to properly classify contracts and subrecipient relationships. Effect The effect of the condition found is that the State may not have properly monitored subrecipients in accordance with State policies and federal requirements. In addition, improper identification of contracts and subrecipients could lead to noncompliance with the State’s procurement policy or the proper monitoring of subrecipients. Questioned Costs None. Recommendation We recommend that the State review its existing internal controls, policies, and procedures to ensure that the State complies with the provisions of 2 CFR section 200.332(a), 2 CFR section 200.332(d through (f), and 2 CFR section 200.251. This would include ensuring that: 1. All required award information is communicated to subrecipients; 2. Ensure that appropriate during the award monitoring is performed as outlined within the subrecipient’s risk assessment; and 3. All subrecipients are reviewed regardless of the amount awarded to determine if a uniform guidance report was issued and if a management decision letter should be issued. In addition, the State should continue to review its vendor determination policy to ensure that the policy is consistently applied across all Department’s within the State. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2023-015 NH Department of Energy Low Income Home Energy Assistance and COVID-19 Low Income Home Energy Assistance (Assistance Listing #93.568) Federal Award Numbers: 2001NHLEA, 2001NHLIE4, 2001NH5C3, 2101NHLIEA, 2101NHE5C6, 2201NHLIEA, 2101NHLIE4, 2201NHLIEE, 2201NHLIEI, 2301NHLIEA, 2301NHLIEE, 2301NHLIEI Federal Award Year: 2020, 2021, 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-025 Statistically Valid Sample: No Criteria A pass-through entity must: 1. Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a); 2. Evaluate each subrecipient’s risk of noncompliance for the purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 300.332(b)); 3. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required through the terms and conditions of the award, subaward monitoring must include following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means; and 4. Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521. Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Low-Income Home Energy Assistance program (LIHEAP), the New Hampshire Department of Energy (the Department) enters into grant agreements with local entities to provide services related to the eligibility determination process for the LIHEAP program (including the calculation of participant benefits) and payment of benefits to fuel providers. During the year ended June 30, 2023, $52,485,098 was passed through to subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following as of the year ending June 30, 2023: A. The Department communicates award information to subrecipients through the approved grant agreement. Per review of the grant agreement, for each of the 3 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated: a. Federal Award Identification Number (FAIN) b. Federal award date c. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414) d. Identification of whether the award is R&D B. For the 1 programmatic monitoring review completed by the Department during the period under audit, the Department did not issue its programmatic monitoring report to the subrecipient timely after the monitoring review was completed. As a result, there was a delay in the subrecipient implementing its corrective action plan to address the findings identified during the programmatic monitoring review. Specifically, we noted the following: a. For the 1 programmatic monitoring review, the monitoring review took place on May 4, 2023, but the report to the subrecipient was not issued until September 23, 2023. Per review of the report that was issued, there were findings identified by the Department that warranted corrective action. Due to the delay in issuing the report, a corrective action plan was not obtained from the subrecipient until almost 5 months after the date of that the monitoring review took place. C. For 3 of 3 subrecipients selected for testwork, the Department did not complete its annual fiscal monitoring review during the audit period as required by their monitoring policy. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted the following: a. The Department does not track the receipt of uniform guidance reports. As a result, we were unable to determine when the uniform guidance reports were received by the Department to ensure they are reviewed timely. Specifically, we noted: i. For all 3 subrecipients selected, the subrecipient’s uniform guidance appeared to have been reviewed, but as the Department does not track the receipt of uniform guidance reports, it was unclear if it was reviewed timely. We did note based on the date that the uniform guidance report was issued, the management decision letter was not issued within 6 months of the date of the report being issued as required by 2 CRF 200.521 (d). ii. For 1 subrecipient in which the UG report had a finding, we were unable to obtain evidence to support that the Department had obtained and reviewed the subrecipient’s uniform guidance report, including management’s response to findings letter as well as the related Corrective Action Plan, as this subrecipient’s uniform guidance report noted a material weakness. E. The Annual Report on Households Assisted by LIHEAP contains data that is specific to benefits paid to eligible participants. The data that is used to compile the annual report is obtained from case data that is reported to the New Hampshire Department of Energy (the Department) from its subrecipients as the Department has entered into grant agreements with third parties who are responsible for the eligibility determination and benefit payment process. As part of our subrecipient monitoring testwork, we were unable to verify that the Department had performed any monitoring procedures over the data provided by each subrecipient to ensure that the data reported within the annual report was complete and accurate. Cause The cause of the condition found was primarily due to insufficient documented subrecipient policies and procedures to ensure that adequate monitoring is performed over subrecipients to align with the risk assessments performed. The monitoring procedures that are in place do not include the completeness and accuracy of the data submitted by the subrecipient utilized to compile federal reports. Further, the Department does not have sufficient internal controls and procedures to ensure results of monitoring visits are performed and results communicated timely to subrecipient or to ensure that subrecipient uniform guidance reports are obtained and reviewed timely. In addition, there are insufficient internal controls in place to review the grant agreements to ensure that all required data elements are communicated to the subrecipient in accordance with 2 CFR section 300.332(b). Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), section 200.332(b) and 2 CFR section 200.521. Questioned Costs None. Recommendation We recommend that the Department formalize, policies and procedures and implement the necessary internal controls to ensure that the Department complies with the provisions of 2 CFR section 200.332(a), 2 CFR section 200.332(b) and 2 CFR section 200.251. This would include ensuring that: 1. All required award information is communicated to subrecipients; 2. As a result of the risk assessment performed, monitoring activities are performed over subrecipients to ensure compliance with the terms and conditions of its subrecipient grant agreement. The results of all monitoring reviews should be timely communicated in accordance with the Department’s policies to the subrecipient and actions requiring corrective action plan should be followed up on to ensure that the matter is resolved; and 3. Ensure that all uniform guidance reports are collected and reviewed timely so that a management decision letter can be issued within the time period required by federal regulations. Retain evidence of Department review of uniform guidance reports and management letters issued as a result of their review. View of Responsible Officials: Management partially concurs with the finding above Rejoinder As it relates to Bullet C above, for 3 of 3 subrecipients selected for testwork, the Department did not complete its annual fiscal monitoring review during the audit period as required by their monitoring policy
Finding Reference Number: 2023-015 NH Department of Energy Low Income Home Energy Assistance and COVID-19 Low Income Home Energy Assistance (Assistance Listing #93.568) Federal Award Numbers: 2001NHLEA, 2001NHLIE4, 2001NH5C3, 2101NHLIEA, 2101NHE5C6, 2201NHLIEA, 2101NHLIE4, 2201NHLIEE, 2201NHLIEI, 2301NHLIEA, 2301NHLIEE, 2301NHLIEI Federal Award Year: 2020, 2021, 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-025 Statistically Valid Sample: No Criteria A pass-through entity must: 1. Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a); 2. Evaluate each subrecipient’s risk of noncompliance for the purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 300.332(b)); 3. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required through the terms and conditions of the award, subaward monitoring must include following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means; and 4. Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521. Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Low-Income Home Energy Assistance program (LIHEAP), the New Hampshire Department of Energy (the Department) enters into grant agreements with local entities to provide services related to the eligibility determination process for the LIHEAP program (including the calculation of participant benefits) and payment of benefits to fuel providers. During the year ended June 30, 2023, $52,485,098 was passed through to subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following as of the year ending June 30, 2023: A. The Department communicates award information to subrecipients through the approved grant agreement. Per review of the grant agreement, for each of the 3 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated: a. Federal Award Identification Number (FAIN) b. Federal award date c. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414) d. Identification of whether the award is R&D B. For the 1 programmatic monitoring review completed by the Department during the period under audit, the Department did not issue its programmatic monitoring report to the subrecipient timely after the monitoring review was completed. As a result, there was a delay in the subrecipient implementing its corrective action plan to address the findings identified during the programmatic monitoring review. Specifically, we noted the following: a. For the 1 programmatic monitoring review, the monitoring review took place on May 4, 2023, but the report to the subrecipient was not issued until September 23, 2023. Per review of the report that was issued, there were findings identified by the Department that warranted corrective action. Due to the delay in issuing the report, a corrective action plan was not obtained from the subrecipient until almost 5 months after the date of that the monitoring review took place. C. For 3 of 3 subrecipients selected for testwork, the Department did not complete its annual fiscal monitoring review during the audit period as required by their monitoring policy. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted the following: a. The Department does not track the receipt of uniform guidance reports. As a result, we were unable to determine when the uniform guidance reports were received by the Department to ensure they are reviewed timely. Specifically, we noted: i. For all 3 subrecipients selected, the subrecipient’s uniform guidance appeared to have been reviewed, but as the Department does not track the receipt of uniform guidance reports, it was unclear if it was reviewed timely. We did note based on the date that the uniform guidance report was issued, the management decision letter was not issued within 6 months of the date of the report being issued as required by 2 CRF 200.521 (d). ii. For 1 subrecipient in which the UG report had a finding, we were unable to obtain evidence to support that the Department had obtained and reviewed the subrecipient’s uniform guidance report, including management’s response to findings letter as well as the related Corrective Action Plan, as this subrecipient’s uniform guidance report noted a material weakness. E. The Annual Report on Households Assisted by LIHEAP contains data that is specific to benefits paid to eligible participants. The data that is used to compile the annual report is obtained from case data that is reported to the New Hampshire Department of Energy (the Department) from its subrecipients as the Department has entered into grant agreements with third parties who are responsible for the eligibility determination and benefit payment process. As part of our subrecipient monitoring testwork, we were unable to verify that the Department had performed any monitoring procedures over the data provided by each subrecipient to ensure that the data reported within the annual report was complete and accurate. Cause The cause of the condition found was primarily due to insufficient documented subrecipient policies and procedures to ensure that adequate monitoring is performed over subrecipients to align with the risk assessments performed. The monitoring procedures that are in place do not include the completeness and accuracy of the data submitted by the subrecipient utilized to compile federal reports. Further, the Department does not have sufficient internal controls and procedures to ensure results of monitoring visits are performed and results communicated timely to subrecipient or to ensure that subrecipient uniform guidance reports are obtained and reviewed timely. In addition, there are insufficient internal controls in place to review the grant agreements to ensure that all required data elements are communicated to the subrecipient in accordance with 2 CFR section 300.332(b). Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), section 200.332(b) and 2 CFR section 200.521. Questioned Costs None. Recommendation We recommend that the Department formalize, policies and procedures and implement the necessary internal controls to ensure that the Department complies with the provisions of 2 CFR section 200.332(a), 2 CFR section 200.332(b) and 2 CFR section 200.251. This would include ensuring that: 1. All required award information is communicated to subrecipients; 2. As a result of the risk assessment performed, monitoring activities are performed over subrecipients to ensure compliance with the terms and conditions of its subrecipient grant agreement. The results of all monitoring reviews should be timely communicated in accordance with the Department’s policies to the subrecipient and actions requiring corrective action plan should be followed up on to ensure that the matter is resolved; and 3. Ensure that all uniform guidance reports are collected and reviewed timely so that a management decision letter can be issued within the time period required by federal regulations. Retain evidence of Department review of uniform guidance reports and management letters issued as a result of their review. View of Responsible Officials: Management partially concurs with the finding above Rejoinder As it relates to Bullet C above, for 3 of 3 subrecipients selected for testwork, the Department did not complete its annual fiscal monitoring review during the audit period as required by their monitoring policy
FINDING 2023-213 The Department erroneously determined that two recipients of Temporary Assistance for Needy Families (TANF) funding were contractors instead of subrecipients resulting in noncompliance with the subrecipient monitoring requirements. Type of Finding: Material Weakness, Material Noncompliance Assistance Listing Title: Temporary Assistance for Needy Families Assistance Listing Number: 93.558 Federal Award Number: 2201IDTANF; 2301IDTANF Program Year: October 1, 2021 – September 30, 2022; October 1, 2022 – September 30, 2023 Federal Agency: Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Questioned Costs: None Criteria: The U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award. The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include items such as approvals, authorizations, verifications, reconciliations, and segregation of duties. The Uniform Guidance included in 2 CFR 200.331 describes the Department’s, a pass-through entity, responsibility for completing subrecipient and contractor determinations. The Uniform Guidance included in 2 CFR 200.332 (a) states that pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward. Also, if any of these data elements change, include the changes in subsequent subaward modification. (1) Federal award identification. (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal award date (see the definition of federal award date in 2 CFR 200.1 of this part) of award to the recipient by the federal agency; (v) Subaward period of performance start and end date; (vi) Subaward budget period start and end date; (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient; (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings number and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listings number at time of disbursement; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the federal award, including if the de minimis rate is charged per 2 CFR 200.414. If any of the required information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. The Uniform Guidance included 2 CFR 200.332(b) states that pass-through entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a single audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of federal awarding agency monitoring (for example, if the subrecipient also receives federal awards directly from a federal awarding agency). Condition: The Department erroneously determined that two recipients of TANF funding were contractors instead of subrecipients. A contractor provides services or goods while a subrecipient has additional responsibilities related to the grant administration. Because of that, there are additional requirements when passing through funds to a subrecipient, rather than making a payment to a vendor. We tested one of the two subrecipients for compliance purposes. The award was not identified to the subrecipient as a subaward and did not include all the necessary information at the time of the subaward. In addition, the subrecipient's risk of noncompliance was not evaluated. Cause: During our analysis of the subrecipient monitoring compliance requirement, we learned that the Department’s program staff determined that some of the recipients of TANF funding were contractors. However, the Department’s financial staff reported the expenditures as payments to subrecipients on the SEFA. After investigation, we found that the expenditures were made to subrecipients, not contractors. Effect: The Department is exposed to increased risk of noncompliance related to subrecipients and improper payments in the TANF program. The Department provided a total amount of $1.4 million to subrecipients during fiscal year 2023. Recommendation: We recommend that the Department implement proper training of personnel involved in subrecipient and contractor determinations. In addition, we recommend that the Department design and implement effective internal control procedures to ensure all required information is provided to subrecipients at the time of subawards and that the Department complete the required evaluations of each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward. Management’s View: The Department agrees with the finding. Corrective Action: The Department has revised our training of personnel involved in subrecipient and contractor determinations. These contract managers and monitors completed grant training on March 12th-13th, 2024 which included sections about subrecipient and contractor determinations, risk assessment and documentation. All newly hired employees will be trained beginning April 2024 with an on-line module. For the impacted vendor, an updated Risk Assessment was completed and submitted to LSO. Additionally, the Department has started the work to effectively change the designation of the vendor and ensure all required information is provided to this subrecipient. This process will be completed by April 30th, 2024. The Department will develop internal control procedures to ensure all required information is provided to the subrecipients at the time of the subawards. These updated internal control procedures will be completed by June 30th, 2024. Auditor’s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
Reference Number: 2023-011 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Human Services Federal Program: Aging Cluster and COVID-19 Aging Cluster Assistance Listing Number: 93.044, 93.045, 93.053 Award Number and Year: 2101NJOASS (10/1/2020 – 9/30/2022) 2101NJOANS (10/1/2020 – 9/30/2022) 2101NJSSC6 (4/1/2021 – 9/30/2024) 2101NJHDC6 (4/1/2021 – 9/3/2024) 2101NJOANS (10/1/2020 – 9/30/2022) 2201NJOASS (10/1/2021 – 9/30/2023) 2201NJOACM (10/1/2021 – 9/30/2023) 2201NJOAHD (10/1/2021-9/30/2023) 2201NJOAPH (10/1/2021-9/30/2023) 2201NJOAFC (10/1/2021-9/30/2023) 2301NJOACM (10/1/2022 – 9/30/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Non-compliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; Section III – Federal Award Findings and Questioned Costs (Continued) xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). Condition: Subawards issued by the Department of Human Services (Department) did not include all required federal award information. Context: For 8 of 8 subawards selected for testing, the following required information was not provided to the subrecipient at the time of award issuance: (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per §200.414 Questioned costs: None noted. Cause: The Department’s procedures were not sufficient to ensure the subawards were issued in compliance with Federal requirements. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Section III – Federal Award Findings and Questioned Costs (Continued) Recommendation: The Department should review and enhance internal controls and procedures to ensure that all required information is included in subawards. Views of responsible officials: The Division of Aging Services (DoAS) will comply with the pass-through entity and subrecipient monitoring requirements under the federal Uniform Guidance as per CFR § 200.332(a). The DoAS will provide all required information to the subrecipient at the time of award issuance. This subaward notice will be posted as a miscellaneous attachment to contracts in the Division's System for Administering Grants Electronically (SAGE), or via mail, fax or email to those subawards not administered in SAGE. DoAS plans to complete and update this information on SAGE within 60 days.
Reference Number: 2023-011 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Human Services Federal Program: Aging Cluster and COVID-19 Aging Cluster Assistance Listing Number: 93.044, 93.045, 93.053 Award Number and Year: 2101NJOASS (10/1/2020 – 9/30/2022) 2101NJOANS (10/1/2020 – 9/30/2022) 2101NJSSC6 (4/1/2021 – 9/30/2024) 2101NJHDC6 (4/1/2021 – 9/3/2024) 2101NJOANS (10/1/2020 – 9/30/2022) 2201NJOASS (10/1/2021 – 9/30/2023) 2201NJOACM (10/1/2021 – 9/30/2023) 2201NJOAHD (10/1/2021-9/30/2023) 2201NJOAPH (10/1/2021-9/30/2023) 2201NJOAFC (10/1/2021-9/30/2023) 2301NJOACM (10/1/2022 – 9/30/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Non-compliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; Section III – Federal Award Findings and Questioned Costs (Continued) xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). Condition: Subawards issued by the Department of Human Services (Department) did not include all required federal award information. Context: For 8 of 8 subawards selected for testing, the following required information was not provided to the subrecipient at the time of award issuance: (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per §200.414 Questioned costs: None noted. Cause: The Department’s procedures were not sufficient to ensure the subawards were issued in compliance with Federal requirements. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Section III – Federal Award Findings and Questioned Costs (Continued) Recommendation: The Department should review and enhance internal controls and procedures to ensure that all required information is included in subawards. Views of responsible officials: The Division of Aging Services (DoAS) will comply with the pass-through entity and subrecipient monitoring requirements under the federal Uniform Guidance as per CFR § 200.332(a). The DoAS will provide all required information to the subrecipient at the time of award issuance. This subaward notice will be posted as a miscellaneous attachment to contracts in the Division's System for Administering Grants Electronically (SAGE), or via mail, fax or email to those subawards not administered in SAGE. DoAS plans to complete and update this information on SAGE within 60 days.
Reference Number: 2023-011 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Human Services Federal Program: Aging Cluster and COVID-19 Aging Cluster Assistance Listing Number: 93.044, 93.045, 93.053 Award Number and Year: 2101NJOASS (10/1/2020 – 9/30/2022) 2101NJOANS (10/1/2020 – 9/30/2022) 2101NJSSC6 (4/1/2021 – 9/30/2024) 2101NJHDC6 (4/1/2021 – 9/3/2024) 2101NJOANS (10/1/2020 – 9/30/2022) 2201NJOASS (10/1/2021 – 9/30/2023) 2201NJOACM (10/1/2021 – 9/30/2023) 2201NJOAHD (10/1/2021-9/30/2023) 2201NJOAPH (10/1/2021-9/30/2023) 2201NJOAFC (10/1/2021-9/30/2023) 2301NJOACM (10/1/2022 – 9/30/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Non-compliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; Section III – Federal Award Findings and Questioned Costs (Continued) xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). Condition: Subawards issued by the Department of Human Services (Department) did not include all required federal award information. Context: For 8 of 8 subawards selected for testing, the following required information was not provided to the subrecipient at the time of award issuance: (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per §200.414 Questioned costs: None noted. Cause: The Department’s procedures were not sufficient to ensure the subawards were issued in compliance with Federal requirements. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Section III – Federal Award Findings and Questioned Costs (Continued) Recommendation: The Department should review and enhance internal controls and procedures to ensure that all required information is included in subawards. Views of responsible officials: The Division of Aging Services (DoAS) will comply with the pass-through entity and subrecipient monitoring requirements under the federal Uniform Guidance as per CFR § 200.332(a). The DoAS will provide all required information to the subrecipient at the time of award issuance. This subaward notice will be posted as a miscellaneous attachment to contracts in the Division's System for Administering Grants Electronically (SAGE), or via mail, fax or email to those subawards not administered in SAGE. DoAS plans to complete and update this information on SAGE within 60 days.
Reference Number: 2023-011 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Human Services Federal Program: Aging Cluster and COVID-19 Aging Cluster Assistance Listing Number: 93.044, 93.045, 93.053 Award Number and Year: 2101NJOASS (10/1/2020 – 9/30/2022) 2101NJOANS (10/1/2020 – 9/30/2022) 2101NJSSC6 (4/1/2021 – 9/30/2024) 2101NJHDC6 (4/1/2021 – 9/3/2024) 2101NJOANS (10/1/2020 – 9/30/2022) 2201NJOASS (10/1/2021 – 9/30/2023) 2201NJOACM (10/1/2021 – 9/30/2023) 2201NJOAHD (10/1/2021-9/30/2023) 2201NJOAPH (10/1/2021-9/30/2023) 2201NJOAFC (10/1/2021-9/30/2023) 2301NJOACM (10/1/2022 – 9/30/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Non-compliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; Section III – Federal Award Findings and Questioned Costs (Continued) xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). Condition: Subawards issued by the Department of Human Services (Department) did not include all required federal award information. Context: For 8 of 8 subawards selected for testing, the following required information was not provided to the subrecipient at the time of award issuance: (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per §200.414 Questioned costs: None noted. Cause: The Department’s procedures were not sufficient to ensure the subawards were issued in compliance with Federal requirements. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Section III – Federal Award Findings and Questioned Costs (Continued) Recommendation: The Department should review and enhance internal controls and procedures to ensure that all required information is included in subawards. Views of responsible officials: The Division of Aging Services (DoAS) will comply with the pass-through entity and subrecipient monitoring requirements under the federal Uniform Guidance as per CFR § 200.332(a). The DoAS will provide all required information to the subrecipient at the time of award issuance. This subaward notice will be posted as a miscellaneous attachment to contracts in the Division's System for Administering Grants Electronically (SAGE), or via mail, fax or email to those subawards not administered in SAGE. DoAS plans to complete and update this information on SAGE within 60 days.
Reference Number: 2023-011 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Human Services Federal Program: Aging Cluster and COVID-19 Aging Cluster Assistance Listing Number: 93.044, 93.045, 93.053 Award Number and Year: 2101NJOASS (10/1/2020 – 9/30/2022) 2101NJOANS (10/1/2020 – 9/30/2022) 2101NJSSC6 (4/1/2021 – 9/30/2024) 2101NJHDC6 (4/1/2021 – 9/3/2024) 2101NJOANS (10/1/2020 – 9/30/2022) 2201NJOASS (10/1/2021 – 9/30/2023) 2201NJOACM (10/1/2021 – 9/30/2023) 2201NJOAHD (10/1/2021-9/30/2023) 2201NJOAPH (10/1/2021-9/30/2023) 2201NJOAFC (10/1/2021-9/30/2023) 2301NJOACM (10/1/2022 – 9/30/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Non-compliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; Section III – Federal Award Findings and Questioned Costs (Continued) xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). Condition: Subawards issued by the Department of Human Services (Department) did not include all required federal award information. Context: For 8 of 8 subawards selected for testing, the following required information was not provided to the subrecipient at the time of award issuance: (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per §200.414 Questioned costs: None noted. Cause: The Department’s procedures were not sufficient to ensure the subawards were issued in compliance with Federal requirements. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Section III – Federal Award Findings and Questioned Costs (Continued) Recommendation: The Department should review and enhance internal controls and procedures to ensure that all required information is included in subawards. Views of responsible officials: The Division of Aging Services (DoAS) will comply with the pass-through entity and subrecipient monitoring requirements under the federal Uniform Guidance as per CFR § 200.332(a). The DoAS will provide all required information to the subrecipient at the time of award issuance. This subaward notice will be posted as a miscellaneous attachment to contracts in the Division's System for Administering Grants Electronically (SAGE), or via mail, fax or email to those subawards not administered in SAGE. DoAS plans to complete and update this information on SAGE within 60 days.
Reference Number: 2023-018 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Community Affairs Federal Program: Low-Income Home Energy Assistance, COVID-19 - Low-Income Home Energy Assistance Assistance Listing Number: 93.568 Award Number and Year: 2102NJE5C6 (3/11/21 – 9/30/22), 2202NJLIEA (10/1/21 – 9/30/22), 2001NJLIEA (10/1/19 – 9/30/22), 2302NJLIEA (10/1/2022 – 9/30/2024), 2302NJLIEI (10/1/2022 – 9/30/2024), 2202NJLIEA (10/1/2021 – 9/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Non-compliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: xv. Subrecipient name (which must match the name associated with its unique entity identifier); xvi. Subrecipient's unique entity identifier; xvii. Federal Award Identification Number (FAIN); xviii. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; xix. Subaward Period of Performance Start and End Date; xx. Subaward Budget Period Start and End Date; xxi. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; xxii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; xxiii. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; xxiv. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xxv. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xxvi. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xxvii. Identification of whether the award is R&D; and xxviii. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. Section III – Federal Award Findings and Questioned Costs (Continued) Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). Condition: Subawards issued by the Department of Community Affairs (Department) did not include all required federal award information. Context: For 8 of 8 subawards selected for testing, the following required information was not provided to the subrecipient at the time of award issuance: (v) Federal Award Identification Number (FAIN); (vi) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (x) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (xi) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (xii) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per §200.414 Questioned costs: None noted. Cause: The Department’s procedures were not sufficient to ensure the subawards were issued in compliance with Federal requirements. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Recommendation: The Department should review and enhance internal controls and procedures to ensure that all required information is included in subawards. Section III – Federal Award Findings and Questioned Costs (Continued) Views of responsible officials: The Department of Community Affairs (DCA) has reviewed and enhanced internal controls and procedures to ensure that all required information, as per the federal Uniform Guidance pass-through entity requirements, is included in all new LIHEAP subaward contracts. These subaward agreement control enhancements have been implemented effective with the fiscal year 2024 contracts.
Reference Number: 2023-018 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Community Affairs Federal Program: Low-Income Home Energy Assistance, COVID-19 - Low-Income Home Energy Assistance Assistance Listing Number: 93.568 Award Number and Year: 2102NJE5C6 (3/11/21 – 9/30/22), 2202NJLIEA (10/1/21 – 9/30/22), 2001NJLIEA (10/1/19 – 9/30/22), 2302NJLIEA (10/1/2022 – 9/30/2024), 2302NJLIEI (10/1/2022 – 9/30/2024), 2202NJLIEA (10/1/2021 – 9/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Non-compliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: xv. Subrecipient name (which must match the name associated with its unique entity identifier); xvi. Subrecipient's unique entity identifier; xvii. Federal Award Identification Number (FAIN); xviii. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; xix. Subaward Period of Performance Start and End Date; xx. Subaward Budget Period Start and End Date; xxi. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; xxii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; xxiii. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; xxiv. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xxv. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xxvi. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xxvii. Identification of whether the award is R&D; and xxviii. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. Section III – Federal Award Findings and Questioned Costs (Continued) Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). Condition: Subawards issued by the Department of Community Affairs (Department) did not include all required federal award information. Context: For 8 of 8 subawards selected for testing, the following required information was not provided to the subrecipient at the time of award issuance: (v) Federal Award Identification Number (FAIN); (vi) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (x) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (xi) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (xii) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per §200.414 Questioned costs: None noted. Cause: The Department’s procedures were not sufficient to ensure the subawards were issued in compliance with Federal requirements. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Recommendation: The Department should review and enhance internal controls and procedures to ensure that all required information is included in subawards. Section III – Federal Award Findings and Questioned Costs (Continued) Views of responsible officials: The Department of Community Affairs (DCA) has reviewed and enhanced internal controls and procedures to ensure that all required information, as per the federal Uniform Guidance pass-through entity requirements, is included in all new LIHEAP subaward contracts. These subaward agreement control enhancements have been implemented effective with the fiscal year 2024 contracts.
Reference Number: 2023-003 Prior Year Finding: No Federal Agency: U.S. Department of Treasury Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: ARP17SL1 (5/23/2021 - 12/31/2026) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Compliance: 2 CFR §200.332 - Requirements for Pass-Through Entities states, in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters. (2) Performing on-site reviews of the subrecipient's program operations. (3) Arranging for agreed-upon-procedures engagements as described in § 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Prince George’s County (the County) was unable to provide support that subawards it issued contained all required federal information nor that it properly monitored its subrecipients. Context: Five subrecipients were selected for testing, and the following exceptions were noted: • For one of five subrecipients, the County did not have a subaward agreement in place with the subrecipient. As such, all required information was not furnished to the subrecipient. • Five of five subaward agreements were missing the following required information: o Federal Award Identification Number (FAIN) • For two of five subrecipients, the County was unable to provide support that it conducted during the award monitoring. • For one of five subrecipients, the County was unable to provide support that it had verified that the subrecipients were audited as required by Subpart F. Questioned costs: Undetermined. Cause: The County did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Not conducting during the award monitoring may result in a failure of the Division to detect that its subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by Division personnel on a timely basis. Recommendation: The County should review and enhance internal controls and procedures to ensure that all required information is included in all subawards, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed. Views of responsible officials: The Office of Community Relations (OCR) is reviewing and working to enhance internal controls and procedures to ensure all required information is included in the subaward, that proper subrecipient monitoring is conducted, and the evaluation of independent audits are performed. OCR is working with the subrecipient to gather payroll receipts and proof of the disbursement of funds to grantees selected through the RFPs managed by the subrecipient.
Reference Number: 2023-003 Prior Year Finding: No Federal Agency: U.S. Department of Treasury Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: ARP17SL1 (5/23/2021 - 12/31/2026) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Compliance: 2 CFR §200.332 - Requirements for Pass-Through Entities states, in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters. (2) Performing on-site reviews of the subrecipient's program operations. (3) Arranging for agreed-upon-procedures engagements as described in § 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Prince George’s County (the County) was unable to provide support that subawards it issued contained all required federal information nor that it properly monitored its subrecipients. Context: Five subrecipients were selected for testing, and the following exceptions were noted: • For one of five subrecipients, the County did not have a subaward agreement in place with the subrecipient. As such, all required information was not furnished to the subrecipient. • Five of five subaward agreements were missing the following required information: o Federal Award Identification Number (FAIN) • For two of five subrecipients, the County was unable to provide support that it conducted during the award monitoring. • For one of five subrecipients, the County was unable to provide support that it had verified that the subrecipients were audited as required by Subpart F. Questioned costs: Undetermined. Cause: The County did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Not conducting during the award monitoring may result in a failure of the Division to detect that its subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by Division personnel on a timely basis. Recommendation: The County should review and enhance internal controls and procedures to ensure that all required information is included in all subawards, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed. Views of responsible officials: The Office of Community Relations (OCR) is reviewing and working to enhance internal controls and procedures to ensure all required information is included in the subaward, that proper subrecipient monitoring is conducted, and the evaluation of independent audits are performed. OCR is working with the subrecipient to gather payroll receipts and proof of the disbursement of funds to grantees selected through the RFPs managed by the subrecipient.
Reference Number: 2023-003 Prior Year Finding: No Federal Agency: U.S. Department of Treasury Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: ARP17SL1 (5/23/2021 - 12/31/2026) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Compliance: 2 CFR §200.332 - Requirements for Pass-Through Entities states, in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters. (2) Performing on-site reviews of the subrecipient's program operations. (3) Arranging for agreed-upon-procedures engagements as described in § 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Prince George’s County (the County) was unable to provide support that subawards it issued contained all required federal information nor that it properly monitored its subrecipients. Context: Five subrecipients were selected for testing, and the following exceptions were noted: • For one of five subrecipients, the County did not have a subaward agreement in place with the subrecipient. As such, all required information was not furnished to the subrecipient. • Five of five subaward agreements were missing the following required information: o Federal Award Identification Number (FAIN) • For two of five subrecipients, the County was unable to provide support that it conducted during the award monitoring. • For one of five subrecipients, the County was unable to provide support that it had verified that the subrecipients were audited as required by Subpart F. Questioned costs: Undetermined. Cause: The County did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Not conducting during the award monitoring may result in a failure of the Division to detect that its subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by Division personnel on a timely basis. Recommendation: The County should review and enhance internal controls and procedures to ensure that all required information is included in all subawards, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed. Views of responsible officials: The Office of Community Relations (OCR) is reviewing and working to enhance internal controls and procedures to ensure all required information is included in the subaward, that proper subrecipient monitoring is conducted, and the evaluation of independent audits are performed. OCR is working with the subrecipient to gather payroll receipts and proof of the disbursement of funds to grantees selected through the RFPs managed by the subrecipient.
Reference Number: 2023-011 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Human Services Federal Program: Aging Cluster and COVID-19 Aging Cluster Assistance Listing Number: 93.044, 93.045, 93.053 Award Number and Year: 2101NJOASS (10/1/2020 – 9/30/2022) 2101NJOANS (10/1/2020 – 9/30/2022) 2101NJSSC6 (4/1/2021 – 9/30/2024) 2101NJHDC6 (4/1/2021 – 9/3/2024) 2101NJOANS (10/1/2020 – 9/30/2022) 2201NJOASS (10/1/2021 – 9/30/2023) 2201NJOACM (10/1/2021 – 9/30/2023) 2201NJOAHD (10/1/2021-9/30/2023) 2201NJOAPH (10/1/2021-9/30/2023) 2201NJOAFC (10/1/2021-9/30/2023) 2301NJOACM (10/1/2022 – 9/30/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Non-compliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; Section III – Federal Award Findings and Questioned Costs (Continued) xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). Condition: Subawards issued by the Department of Human Services (Department) did not include all required federal award information. Context: For 8 of 8 subawards selected for testing, the following required information was not provided to the subrecipient at the time of award issuance: (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per §200.414 Questioned costs: None noted. Cause: The Department’s procedures were not sufficient to ensure the subawards were issued in compliance with Federal requirements. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Section III – Federal Award Findings and Questioned Costs (Continued) Recommendation: The Department should review and enhance internal controls and procedures to ensure that all required information is included in subawards. Views of responsible officials: The Division of Aging Services (DoAS) will comply with the pass-through entity and subrecipient monitoring requirements under the federal Uniform Guidance as per CFR § 200.332(a). The DoAS will provide all required information to the subrecipient at the time of award issuance. This subaward notice will be posted as a miscellaneous attachment to contracts in the Division's System for Administering Grants Electronically (SAGE), or via mail, fax or email to those subawards not administered in SAGE. DoAS plans to complete and update this information on SAGE within 60 days.
Reference Number: 2023-011 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Human Services Federal Program: Aging Cluster and COVID-19 Aging Cluster Assistance Listing Number: 93.044, 93.045, 93.053 Award Number and Year: 2101NJOASS (10/1/2020 – 9/30/2022) 2101NJOANS (10/1/2020 – 9/30/2022) 2101NJSSC6 (4/1/2021 – 9/30/2024) 2101NJHDC6 (4/1/2021 – 9/3/2024) 2101NJOANS (10/1/2020 – 9/30/2022) 2201NJOASS (10/1/2021 – 9/30/2023) 2201NJOACM (10/1/2021 – 9/30/2023) 2201NJOAHD (10/1/2021-9/30/2023) 2201NJOAPH (10/1/2021-9/30/2023) 2201NJOAFC (10/1/2021-9/30/2023) 2301NJOACM (10/1/2022 – 9/30/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Non-compliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; Section III – Federal Award Findings and Questioned Costs (Continued) xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). Condition: Subawards issued by the Department of Human Services (Department) did not include all required federal award information. Context: For 8 of 8 subawards selected for testing, the following required information was not provided to the subrecipient at the time of award issuance: (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per §200.414 Questioned costs: None noted. Cause: The Department’s procedures were not sufficient to ensure the subawards were issued in compliance with Federal requirements. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Section III – Federal Award Findings and Questioned Costs (Continued) Recommendation: The Department should review and enhance internal controls and procedures to ensure that all required information is included in subawards. Views of responsible officials: The Division of Aging Services (DoAS) will comply with the pass-through entity and subrecipient monitoring requirements under the federal Uniform Guidance as per CFR § 200.332(a). The DoAS will provide all required information to the subrecipient at the time of award issuance. This subaward notice will be posted as a miscellaneous attachment to contracts in the Division's System for Administering Grants Electronically (SAGE), or via mail, fax or email to those subawards not administered in SAGE. DoAS plans to complete and update this information on SAGE within 60 days.
Reference Number: 2023-011 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Human Services Federal Program: Aging Cluster and COVID-19 Aging Cluster Assistance Listing Number: 93.044, 93.045, 93.053 Award Number and Year: 2101NJOASS (10/1/2020 – 9/30/2022) 2101NJOANS (10/1/2020 – 9/30/2022) 2101NJSSC6 (4/1/2021 – 9/30/2024) 2101NJHDC6 (4/1/2021 – 9/3/2024) 2101NJOANS (10/1/2020 – 9/30/2022) 2201NJOASS (10/1/2021 – 9/30/2023) 2201NJOACM (10/1/2021 – 9/30/2023) 2201NJOAHD (10/1/2021-9/30/2023) 2201NJOAPH (10/1/2021-9/30/2023) 2201NJOAFC (10/1/2021-9/30/2023) 2301NJOACM (10/1/2022 – 9/30/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Non-compliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; Section III – Federal Award Findings and Questioned Costs (Continued) xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). Condition: Subawards issued by the Department of Human Services (Department) did not include all required federal award information. Context: For 8 of 8 subawards selected for testing, the following required information was not provided to the subrecipient at the time of award issuance: (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per §200.414 Questioned costs: None noted. Cause: The Department’s procedures were not sufficient to ensure the subawards were issued in compliance with Federal requirements. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Section III – Federal Award Findings and Questioned Costs (Continued) Recommendation: The Department should review and enhance internal controls and procedures to ensure that all required information is included in subawards. Views of responsible officials: The Division of Aging Services (DoAS) will comply with the pass-through entity and subrecipient monitoring requirements under the federal Uniform Guidance as per CFR § 200.332(a). The DoAS will provide all required information to the subrecipient at the time of award issuance. This subaward notice will be posted as a miscellaneous attachment to contracts in the Division's System for Administering Grants Electronically (SAGE), or via mail, fax or email to those subawards not administered in SAGE. DoAS plans to complete and update this information on SAGE within 60 days.
Reference Number: 2023-011 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Human Services Federal Program: Aging Cluster and COVID-19 Aging Cluster Assistance Listing Number: 93.044, 93.045, 93.053 Award Number and Year: 2101NJOASS (10/1/2020 – 9/30/2022) 2101NJOANS (10/1/2020 – 9/30/2022) 2101NJSSC6 (4/1/2021 – 9/30/2024) 2101NJHDC6 (4/1/2021 – 9/3/2024) 2101NJOANS (10/1/2020 – 9/30/2022) 2201NJOASS (10/1/2021 – 9/30/2023) 2201NJOACM (10/1/2021 – 9/30/2023) 2201NJOAHD (10/1/2021-9/30/2023) 2201NJOAPH (10/1/2021-9/30/2023) 2201NJOAFC (10/1/2021-9/30/2023) 2301NJOACM (10/1/2022 – 9/30/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Non-compliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; Section III – Federal Award Findings and Questioned Costs (Continued) xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). Condition: Subawards issued by the Department of Human Services (Department) did not include all required federal award information. Context: For 8 of 8 subawards selected for testing, the following required information was not provided to the subrecipient at the time of award issuance: (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per §200.414 Questioned costs: None noted. Cause: The Department’s procedures were not sufficient to ensure the subawards were issued in compliance with Federal requirements. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Section III – Federal Award Findings and Questioned Costs (Continued) Recommendation: The Department should review and enhance internal controls and procedures to ensure that all required information is included in subawards. Views of responsible officials: The Division of Aging Services (DoAS) will comply with the pass-through entity and subrecipient monitoring requirements under the federal Uniform Guidance as per CFR § 200.332(a). The DoAS will provide all required information to the subrecipient at the time of award issuance. This subaward notice will be posted as a miscellaneous attachment to contracts in the Division's System for Administering Grants Electronically (SAGE), or via mail, fax or email to those subawards not administered in SAGE. DoAS plans to complete and update this information on SAGE within 60 days.
Reference Number: 2023-011 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Human Services Federal Program: Aging Cluster and COVID-19 Aging Cluster Assistance Listing Number: 93.044, 93.045, 93.053 Award Number and Year: 2101NJOASS (10/1/2020 – 9/30/2022) 2101NJOANS (10/1/2020 – 9/30/2022) 2101NJSSC6 (4/1/2021 – 9/30/2024) 2101NJHDC6 (4/1/2021 – 9/3/2024) 2101NJOANS (10/1/2020 – 9/30/2022) 2201NJOASS (10/1/2021 – 9/30/2023) 2201NJOACM (10/1/2021 – 9/30/2023) 2201NJOAHD (10/1/2021-9/30/2023) 2201NJOAPH (10/1/2021-9/30/2023) 2201NJOAFC (10/1/2021-9/30/2023) 2301NJOACM (10/1/2022 – 9/30/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Non-compliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; Section III – Federal Award Findings and Questioned Costs (Continued) xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). Condition: Subawards issued by the Department of Human Services (Department) did not include all required federal award information. Context: For 8 of 8 subawards selected for testing, the following required information was not provided to the subrecipient at the time of award issuance: (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per §200.414 Questioned costs: None noted. Cause: The Department’s procedures were not sufficient to ensure the subawards were issued in compliance with Federal requirements. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Section III – Federal Award Findings and Questioned Costs (Continued) Recommendation: The Department should review and enhance internal controls and procedures to ensure that all required information is included in subawards. Views of responsible officials: The Division of Aging Services (DoAS) will comply with the pass-through entity and subrecipient monitoring requirements under the federal Uniform Guidance as per CFR § 200.332(a). The DoAS will provide all required information to the subrecipient at the time of award issuance. This subaward notice will be posted as a miscellaneous attachment to contracts in the Division's System for Administering Grants Electronically (SAGE), or via mail, fax or email to those subawards not administered in SAGE. DoAS plans to complete and update this information on SAGE within 60 days.
Reference Number: 2023-018 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Community Affairs Federal Program: Low-Income Home Energy Assistance, COVID-19 - Low-Income Home Energy Assistance Assistance Listing Number: 93.568 Award Number and Year: 2102NJE5C6 (3/11/21 – 9/30/22), 2202NJLIEA (10/1/21 – 9/30/22), 2001NJLIEA (10/1/19 – 9/30/22), 2302NJLIEA (10/1/2022 – 9/30/2024), 2302NJLIEI (10/1/2022 – 9/30/2024), 2202NJLIEA (10/1/2021 – 9/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Non-compliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: xv. Subrecipient name (which must match the name associated with its unique entity identifier); xvi. Subrecipient's unique entity identifier; xvii. Federal Award Identification Number (FAIN); xviii. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; xix. Subaward Period of Performance Start and End Date; xx. Subaward Budget Period Start and End Date; xxi. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; xxii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; xxiii. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; xxiv. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xxv. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xxvi. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xxvii. Identification of whether the award is R&D; and xxviii. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. Section III – Federal Award Findings and Questioned Costs (Continued) Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). Condition: Subawards issued by the Department of Community Affairs (Department) did not include all required federal award information. Context: For 8 of 8 subawards selected for testing, the following required information was not provided to the subrecipient at the time of award issuance: (v) Federal Award Identification Number (FAIN); (vi) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (x) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (xi) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (xii) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per §200.414 Questioned costs: None noted. Cause: The Department’s procedures were not sufficient to ensure the subawards were issued in compliance with Federal requirements. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Recommendation: The Department should review and enhance internal controls and procedures to ensure that all required information is included in subawards. Section III – Federal Award Findings and Questioned Costs (Continued) Views of responsible officials: The Department of Community Affairs (DCA) has reviewed and enhanced internal controls and procedures to ensure that all required information, as per the federal Uniform Guidance pass-through entity requirements, is included in all new LIHEAP subaward contracts. These subaward agreement control enhancements have been implemented effective with the fiscal year 2024 contracts.
Reference Number: 2023-018 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Community Affairs Federal Program: Low-Income Home Energy Assistance, COVID-19 - Low-Income Home Energy Assistance Assistance Listing Number: 93.568 Award Number and Year: 2102NJE5C6 (3/11/21 – 9/30/22), 2202NJLIEA (10/1/21 – 9/30/22), 2001NJLIEA (10/1/19 – 9/30/22), 2302NJLIEA (10/1/2022 – 9/30/2024), 2302NJLIEI (10/1/2022 – 9/30/2024), 2202NJLIEA (10/1/2021 – 9/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Non-compliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: xv. Subrecipient name (which must match the name associated with its unique entity identifier); xvi. Subrecipient's unique entity identifier; xvii. Federal Award Identification Number (FAIN); xviii. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; xix. Subaward Period of Performance Start and End Date; xx. Subaward Budget Period Start and End Date; xxi. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; xxii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; xxiii. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; xxiv. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xxv. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xxvi. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xxvii. Identification of whether the award is R&D; and xxviii. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. Section III – Federal Award Findings and Questioned Costs (Continued) Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). Condition: Subawards issued by the Department of Community Affairs (Department) did not include all required federal award information. Context: For 8 of 8 subawards selected for testing, the following required information was not provided to the subrecipient at the time of award issuance: (v) Federal Award Identification Number (FAIN); (vi) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (x) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (xi) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (xii) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per §200.414 Questioned costs: None noted. Cause: The Department’s procedures were not sufficient to ensure the subawards were issued in compliance with Federal requirements. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Recommendation: The Department should review and enhance internal controls and procedures to ensure that all required information is included in subawards. Section III – Federal Award Findings and Questioned Costs (Continued) Views of responsible officials: The Department of Community Affairs (DCA) has reviewed and enhanced internal controls and procedures to ensure that all required information, as per the federal Uniform Guidance pass-through entity requirements, is included in all new LIHEAP subaward contracts. These subaward agreement control enhancements have been implemented effective with the fiscal year 2024 contracts.
Federal Awarding Agency: U.S. Department of Interior Impact: Significant Deficiency, Noncompliance AL Number and Title: 15.800 Research and Development Cluster Federal Award Number: G22AC00562-00 Applicable Compliance Requirement: Allowable Costs/Cost Principles Condition and Context: During testing of Indirect Cost Rate calculations, one grant from the University of Alaska Southeast campus (UAS) had one instance of an incorrect indirect cost rate calculation. UAS had two different applicable rates for on-campus and off-campus activity. The campus used the on-campus rate for both activities resulting in a higher calculated indirect cost. Cause: The internal control process for the creation of new funds auto-populated the indirect cost rate incorrectly by using the on-campus rate of 59.7 for both on-campus and off-campus research activities. Criteria: Per 2 CFR 200.414 the indirect cost methodology must be consistent with the cost accounting policy and negotiated rate agreement. Effect: An incorrect indirect cost was calculated and charged to the grant. Questioned Costs: $1,630 Recommendation: UAS should review the indirect cost rates populated for new grant funds to ensure correct rates are used. View of Responsible Officials: Management agrees with this finding.
Reference Number: 2023-005 Prior Year Finding: 2022-004 Federal Agency: U.S. Department of Agriculture State Agency: Department of Elementary and Secondary Education Federal Program: Child and Adult Care Food Program Assistance Listing Number: 10.558 Award Number and Year: 202222N202044 (10/1/2021 – 9/30/2022), 202323N202044 (10/1/2022 – 9/30/2023), 202323N119944 (1/1/2022 – 9/30/2023), 202323N202044 (10/1/2022 – 9/30/2023), 202323N119944 (10/1/2022 – 9/30/2023) Compliance Requirement: Eligibility, Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or Specific Requirement: Compliance: Eligibility – Per 7 CFR section 226.2, subrecipients must meet the definition of “independent center” or “sponsoring organization”. In addition, all institutions must also meet the eligibility requirements stated in 7 CFR section 226.15 and 42 USC 1766(a)(6) and (d)(l). Definitions include: 1) Independent center means a child care center, at-risk afterschool care center, emergency shelter, outside-school-hours care center or adult day care center which enters into an agreement with the state agency to assume final administrative and financial responsibility for program operations. 2) Sponsoring organization means a public or nonprofit private organization that is entirely responsible for the administration of the food program. 3) For-profit center means a child care center, outside-school-hours care center, or adult day care center providing nonresidential care to adults or children that does not qualify for tax-exempt status under the Internal Revenue Code of 1986. For-profit centers serving adults must meet the criteria described in paragraph (a) of this definition. For-profit centers serving children must meet the criteria described in paragraphs (b )(1) or (b )(2) of this definition, except that children who only participate in the at-risk afterschool snack and/or meal component of the program must not be considered in determining the percentages under paragraphs (b )( 1) or (b)(2) of this definition. Subrecipient Monitoring – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Elementary and Secondary Education (Department) was unable to provide documentation that it issued subawards in compliance with federal regulations. Context: Sixty subawards were selected for testing. The Department documents subrecipient eligibility in a permanent agreement with each subrecipient. The following exceptions were noted: • For one of sixty subawards selected for testing, the Department could not provide documentation that it had obtained the subrecipient’s Unique Entity Identifier prior to the issuance of the subaward. • For six of sixty subrecipients selected for testing, the Department did not have an approved permanent agreement on file prior to the start date of the contract. Therefore, the Department was unable to provide documentation that it had determined subrecipient eligibility prior to the start date of the contract. Questioned costs: Undetermined. Cause: The Department’s procedures and controls were not sufficient to ensure that subawards were issued in compliance with federal regulations and that subrecipient eligibility was determined prior to issuance of contracts. Effect: Failure to ensure subrecipients are eligible to receive program funding and failure to ensure subrecipients have a registered unique entity identification number could result in unauthorized entities receiving program funding. Recommendation: The Department should review and enhance internal controls and procedures to ensure that all subrecipients are eligible to receive program funds and that required information is obtained prior to entering into a subrecipient agreement. Views of Responsible Officials: Management agrees with the finding.
Reference Number: 2023-005 Prior Year Finding: 2022-004 Federal Agency: U.S. Department of Agriculture State Agency: Department of Elementary and Secondary Education Federal Program: Child and Adult Care Food Program Assistance Listing Number: 10.558 Award Number and Year: 202222N202044 (10/1/2021 – 9/30/2022), 202323N202044 (10/1/2022 – 9/30/2023), 202323N119944 (1/1/2022 – 9/30/2023), 202323N202044 (10/1/2022 – 9/30/2023), 202323N119944 (10/1/2022 – 9/30/2023) Compliance Requirement: Eligibility, Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or Specific Requirement: Compliance: Eligibility – Per 7 CFR section 226.2, subrecipients must meet the definition of “independent center” or “sponsoring organization”. In addition, all institutions must also meet the eligibility requirements stated in 7 CFR section 226.15 and 42 USC 1766(a)(6) and (d)(l). Definitions include: 1) Independent center means a child care center, at-risk afterschool care center, emergency shelter, outside-school-hours care center or adult day care center which enters into an agreement with the state agency to assume final administrative and financial responsibility for program operations. 2) Sponsoring organization means a public or nonprofit private organization that is entirely responsible for the administration of the food program. 3) For-profit center means a child care center, outside-school-hours care center, or adult day care center providing nonresidential care to adults or children that does not qualify for tax-exempt status under the Internal Revenue Code of 1986. For-profit centers serving adults must meet the criteria described in paragraph (a) of this definition. For-profit centers serving children must meet the criteria described in paragraphs (b )(1) or (b )(2) of this definition, except that children who only participate in the at-risk afterschool snack and/or meal component of the program must not be considered in determining the percentages under paragraphs (b )( 1) or (b)(2) of this definition. Subrecipient Monitoring – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Elementary and Secondary Education (Department) was unable to provide documentation that it issued subawards in compliance with federal regulations. Context: Sixty subawards were selected for testing. The Department documents subrecipient eligibility in a permanent agreement with each subrecipient. The following exceptions were noted: • For one of sixty subawards selected for testing, the Department could not provide documentation that it had obtained the subrecipient’s Unique Entity Identifier prior to the issuance of the subaward. • For six of sixty subrecipients selected for testing, the Department did not have an approved permanent agreement on file prior to the start date of the contract. Therefore, the Department was unable to provide documentation that it had determined subrecipient eligibility prior to the start date of the contract. Questioned costs: Undetermined. Cause: The Department’s procedures and controls were not sufficient to ensure that subawards were issued in compliance with federal regulations and that subrecipient eligibility was determined prior to issuance of contracts. Effect: Failure to ensure subrecipients are eligible to receive program funding and failure to ensure subrecipients have a registered unique entity identification number could result in unauthorized entities receiving program funding. Recommendation: The Department should review and enhance internal controls and procedures to ensure that all subrecipients are eligible to receive program funds and that required information is obtained prior to entering into a subrecipient agreement. Views of Responsible Officials: Management agrees with the finding.
Finding Reference Number: 2023-005 NH Department of Justice NH Department of Health and Human Services NH Department of Environmental Services NH Department of Business and Economic Affairs COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing #21.027) Federal Award Numbers: SLFRP0145 Federal Award Year: 2021 U.S. Department of Treasury Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-008 Statistically Valid Sample: No Criteria A pass-through entity must: 1. Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a); 2. Evaluate each subrecipient’s risk of noncompliance for the purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 300.332(b)); 3. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorization purposes, complies with the terms and conditions of the subaward 4. Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. Condition As part of the Coronavirus State and Local Fiscal Recovery Funds program, the State of New Hampshire (the State) entered into grant agreements with local entities to support allowable activities under the federal program. During the year ended June 30, 2022, the State passed through $73,337,682 to subrecipients. As part of our testwork over the subrecipient monitoring process, we identified the following breakdown of internal controls: A. As part of our testwork over subrecipient monitoring, we selected a sample of 49 items from the listing of subrecipients provided by the State that reconciled to the amount reported on the Schedule of Expenditures of Federal Awards. Of the 49 items selected for testwork, 6 items were contracts and were not subrecipient agreements. As such, we were unable to determine the completeness and accuracy of the subrecipient population. As a result of our audit, the State identified that this error resulted in the amount reported on the Schedule of Expenditures of Federal Awards as pass-through expenditures to be overstated by $7,261,684. The State has corrected the Schedule of Expenditures of Federal Awards so that the amount reported is accurate. B. The State communicates award information to subrecipients through the approved grant agreement. For 19 of the 43 remaining subrecipients selected for testwork, the State did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated: a. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414) was not communicated for 19 of the 43 remaining subrecipients selected for testwork. b. Identification of whether the award is R&D was not communicated for 17 of the remaining 43 subrecipients selected for testwork. C. As part of our testwork over during the award monitoring, it was identified that subrecipient monitoring activities include the review and approval of invoices submitted for reimbursement from the subrecipient. During our testwork over the invoice review we identified the following: a. For 6 of the remaining 43 subrecipients selected for testwork, we were unable to obtain the invoices paid by the State to verify that they were reviewed and approved. While the invoices were not provided to us, we noted that other monitoring procedures were performed for 4 of the 6 subrecipients. b. For 10 of the remaining 43 subrecipients selected for testwork, while we were able to obtain the invoices paid by the State, we were unable to properly identify who the appropriate reviewer was for the invoice to ensure that the individual who approved the invoice had the appropriate knowledge and competency to perform the review process. As a result, we were unable to verify if the invoice was appropriately reviewed. While we were unable to verify this, we noted that other monitoring procedures were performed for 9 of the 10 subrecipients. D. As part of our testwork over during the award monitoring, for 9 of the 43 remaining subrecipients selected for testwork, no documentation was provided to support that during the award monitoring procedures had been performed during the audit period. As such, we could not verify that appropriate monitoring procedures were performed as outlined by the subrecipient’s risk assessment. E. As part of our testwork over the review of Uniform Guidance Reports, we identified the following: a. For 6 of the remaining 43 subrecipients selected for testwork, the State provided the subrecipients Uniform Guidance report, however there was no evidence that the reports were reviewed to determine if a management decision letter needed to be issued. As part of our audit, we reviewed the 6 uniform guidance reports and did not identify any findings that would have required to be followed up on by the State. b. For 7 of the remaining 43 subrecipients selected for testwork, the subrecipient’s uniform guidance report was not provided. We reviewed the FAC to determine if a report was submitted during the audit period and identified that all 7 subrecipients had submitted a uniform guidance report. Of the 7 subrecipients, 1 report contained findings reported within Section III of the report. There was no evidence provided that the State had issued a management decision related to this subrecipient. Cause The cause of the condition found is primarily due to insufficient internal controls and procedures to ensure that award identification information is communicated, that appropriate during the award monitoring is performed based on the risk assessments and that all subrecipients are reviewed to determine if a uniform guidance audit was issued regardless of amount awarded to the subrecipient. Given the nature of this program, several Departments within the State entered into subrecipient grants resulting in a decentralized process. Not all Departments within the State are experienced with subrecipient relationships and may not have had developed policies to comply with subrecipient monitoring requirements. Finally, the State does not have sufficient internal controls in place to properly classify contracts and subrecipient relationships. Effect The effect of the condition found is that the State may not have properly monitored subrecipients in accordance with State policies and federal requirements. In addition, improper identification of contracts and subrecipients could lead to noncompliance with the State’s procurement policy or the proper monitoring of subrecipients. Questioned Costs None. Recommendation We recommend that the State review its existing internal controls, policies, and procedures to ensure that the State complies with the provisions of 2 CFR section 200.332(a), 2 CFR section 200.332(d through (f), and 2 CFR section 200.251. This would include ensuring that: 1. All required award information is communicated to subrecipients; 2. Ensure that appropriate during the award monitoring is performed as outlined within the subrecipient’s risk assessment; and 3. All subrecipients are reviewed regardless of the amount awarded to determine if a uniform guidance report was issued and if a management decision letter should be issued. In addition, the State should continue to review its vendor determination policy to ensure that the policy is consistently applied across all Department’s within the State. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2023-015 NH Department of Energy Low Income Home Energy Assistance and COVID-19 Low Income Home Energy Assistance (Assistance Listing #93.568) Federal Award Numbers: 2001NHLEA, 2001NHLIE4, 2001NH5C3, 2101NHLIEA, 2101NHE5C6, 2201NHLIEA, 2101NHLIE4, 2201NHLIEE, 2201NHLIEI, 2301NHLIEA, 2301NHLIEE, 2301NHLIEI Federal Award Year: 2020, 2021, 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-025 Statistically Valid Sample: No Criteria A pass-through entity must: 1. Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a); 2. Evaluate each subrecipient’s risk of noncompliance for the purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 300.332(b)); 3. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required through the terms and conditions of the award, subaward monitoring must include following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means; and 4. Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521. Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Low-Income Home Energy Assistance program (LIHEAP), the New Hampshire Department of Energy (the Department) enters into grant agreements with local entities to provide services related to the eligibility determination process for the LIHEAP program (including the calculation of participant benefits) and payment of benefits to fuel providers. During the year ended June 30, 2023, $52,485,098 was passed through to subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following as of the year ending June 30, 2023: A. The Department communicates award information to subrecipients through the approved grant agreement. Per review of the grant agreement, for each of the 3 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated: a. Federal Award Identification Number (FAIN) b. Federal award date c. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414) d. Identification of whether the award is R&D B. For the 1 programmatic monitoring review completed by the Department during the period under audit, the Department did not issue its programmatic monitoring report to the subrecipient timely after the monitoring review was completed. As a result, there was a delay in the subrecipient implementing its corrective action plan to address the findings identified during the programmatic monitoring review. Specifically, we noted the following: a. For the 1 programmatic monitoring review, the monitoring review took place on May 4, 2023, but the report to the subrecipient was not issued until September 23, 2023. Per review of the report that was issued, there were findings identified by the Department that warranted corrective action. Due to the delay in issuing the report, a corrective action plan was not obtained from the subrecipient until almost 5 months after the date of that the monitoring review took place. C. For 3 of 3 subrecipients selected for testwork, the Department did not complete its annual fiscal monitoring review during the audit period as required by their monitoring policy. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted the following: a. The Department does not track the receipt of uniform guidance reports. As a result, we were unable to determine when the uniform guidance reports were received by the Department to ensure they are reviewed timely. Specifically, we noted: i. For all 3 subrecipients selected, the subrecipient’s uniform guidance appeared to have been reviewed, but as the Department does not track the receipt of uniform guidance reports, it was unclear if it was reviewed timely. We did note based on the date that the uniform guidance report was issued, the management decision letter was not issued within 6 months of the date of the report being issued as required by 2 CRF 200.521 (d). ii. For 1 subrecipient in which the UG report had a finding, we were unable to obtain evidence to support that the Department had obtained and reviewed the subrecipient’s uniform guidance report, including management’s response to findings letter as well as the related Corrective Action Plan, as this subrecipient’s uniform guidance report noted a material weakness. E. The Annual Report on Households Assisted by LIHEAP contains data that is specific to benefits paid to eligible participants. The data that is used to compile the annual report is obtained from case data that is reported to the New Hampshire Department of Energy (the Department) from its subrecipients as the Department has entered into grant agreements with third parties who are responsible for the eligibility determination and benefit payment process. As part of our subrecipient monitoring testwork, we were unable to verify that the Department had performed any monitoring procedures over the data provided by each subrecipient to ensure that the data reported within the annual report was complete and accurate. Cause The cause of the condition found was primarily due to insufficient documented subrecipient policies and procedures to ensure that adequate monitoring is performed over subrecipients to align with the risk assessments performed. The monitoring procedures that are in place do not include the completeness and accuracy of the data submitted by the subrecipient utilized to compile federal reports. Further, the Department does not have sufficient internal controls and procedures to ensure results of monitoring visits are performed and results communicated timely to subrecipient or to ensure that subrecipient uniform guidance reports are obtained and reviewed timely. In addition, there are insufficient internal controls in place to review the grant agreements to ensure that all required data elements are communicated to the subrecipient in accordance with 2 CFR section 300.332(b). Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), section 200.332(b) and 2 CFR section 200.521. Questioned Costs None. Recommendation We recommend that the Department formalize, policies and procedures and implement the necessary internal controls to ensure that the Department complies with the provisions of 2 CFR section 200.332(a), 2 CFR section 200.332(b) and 2 CFR section 200.251. This would include ensuring that: 1. All required award information is communicated to subrecipients; 2. As a result of the risk assessment performed, monitoring activities are performed over subrecipients to ensure compliance with the terms and conditions of its subrecipient grant agreement. The results of all monitoring reviews should be timely communicated in accordance with the Department’s policies to the subrecipient and actions requiring corrective action plan should be followed up on to ensure that the matter is resolved; and 3. Ensure that all uniform guidance reports are collected and reviewed timely so that a management decision letter can be issued within the time period required by federal regulations. Retain evidence of Department review of uniform guidance reports and management letters issued as a result of their review. View of Responsible Officials: Management partially concurs with the finding above Rejoinder As it relates to Bullet C above, for 3 of 3 subrecipients selected for testwork, the Department did not complete its annual fiscal monitoring review during the audit period as required by their monitoring policy
Finding Reference Number: 2023-015 NH Department of Energy Low Income Home Energy Assistance and COVID-19 Low Income Home Energy Assistance (Assistance Listing #93.568) Federal Award Numbers: 2001NHLEA, 2001NHLIE4, 2001NH5C3, 2101NHLIEA, 2101NHE5C6, 2201NHLIEA, 2101NHLIE4, 2201NHLIEE, 2201NHLIEI, 2301NHLIEA, 2301NHLIEE, 2301NHLIEI Federal Award Year: 2020, 2021, 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-025 Statistically Valid Sample: No Criteria A pass-through entity must: 1. Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a); 2. Evaluate each subrecipient’s risk of noncompliance for the purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 300.332(b)); 3. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required through the terms and conditions of the award, subaward monitoring must include following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means; and 4. Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521. Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Low-Income Home Energy Assistance program (LIHEAP), the New Hampshire Department of Energy (the Department) enters into grant agreements with local entities to provide services related to the eligibility determination process for the LIHEAP program (including the calculation of participant benefits) and payment of benefits to fuel providers. During the year ended June 30, 2023, $52,485,098 was passed through to subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following as of the year ending June 30, 2023: A. The Department communicates award information to subrecipients through the approved grant agreement. Per review of the grant agreement, for each of the 3 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated: a. Federal Award Identification Number (FAIN) b. Federal award date c. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414) d. Identification of whether the award is R&D B. For the 1 programmatic monitoring review completed by the Department during the period under audit, the Department did not issue its programmatic monitoring report to the subrecipient timely after the monitoring review was completed. As a result, there was a delay in the subrecipient implementing its corrective action plan to address the findings identified during the programmatic monitoring review. Specifically, we noted the following: a. For the 1 programmatic monitoring review, the monitoring review took place on May 4, 2023, but the report to the subrecipient was not issued until September 23, 2023. Per review of the report that was issued, there were findings identified by the Department that warranted corrective action. Due to the delay in issuing the report, a corrective action plan was not obtained from the subrecipient until almost 5 months after the date of that the monitoring review took place. C. For 3 of 3 subrecipients selected for testwork, the Department did not complete its annual fiscal monitoring review during the audit period as required by their monitoring policy. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted the following: a. The Department does not track the receipt of uniform guidance reports. As a result, we were unable to determine when the uniform guidance reports were received by the Department to ensure they are reviewed timely. Specifically, we noted: i. For all 3 subrecipients selected, the subrecipient’s uniform guidance appeared to have been reviewed, but as the Department does not track the receipt of uniform guidance reports, it was unclear if it was reviewed timely. We did note based on the date that the uniform guidance report was issued, the management decision letter was not issued within 6 months of the date of the report being issued as required by 2 CRF 200.521 (d). ii. For 1 subrecipient in which the UG report had a finding, we were unable to obtain evidence to support that the Department had obtained and reviewed the subrecipient’s uniform guidance report, including management’s response to findings letter as well as the related Corrective Action Plan, as this subrecipient’s uniform guidance report noted a material weakness. E. The Annual Report on Households Assisted by LIHEAP contains data that is specific to benefits paid to eligible participants. The data that is used to compile the annual report is obtained from case data that is reported to the New Hampshire Department of Energy (the Department) from its subrecipients as the Department has entered into grant agreements with third parties who are responsible for the eligibility determination and benefit payment process. As part of our subrecipient monitoring testwork, we were unable to verify that the Department had performed any monitoring procedures over the data provided by each subrecipient to ensure that the data reported within the annual report was complete and accurate. Cause The cause of the condition found was primarily due to insufficient documented subrecipient policies and procedures to ensure that adequate monitoring is performed over subrecipients to align with the risk assessments performed. The monitoring procedures that are in place do not include the completeness and accuracy of the data submitted by the subrecipient utilized to compile federal reports. Further, the Department does not have sufficient internal controls and procedures to ensure results of monitoring visits are performed and results communicated timely to subrecipient or to ensure that subrecipient uniform guidance reports are obtained and reviewed timely. In addition, there are insufficient internal controls in place to review the grant agreements to ensure that all required data elements are communicated to the subrecipient in accordance with 2 CFR section 300.332(b). Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), section 200.332(b) and 2 CFR section 200.521. Questioned Costs None. Recommendation We recommend that the Department formalize, policies and procedures and implement the necessary internal controls to ensure that the Department complies with the provisions of 2 CFR section 200.332(a), 2 CFR section 200.332(b) and 2 CFR section 200.251. This would include ensuring that: 1. All required award information is communicated to subrecipients; 2. As a result of the risk assessment performed, monitoring activities are performed over subrecipients to ensure compliance with the terms and conditions of its subrecipient grant agreement. The results of all monitoring reviews should be timely communicated in accordance with the Department’s policies to the subrecipient and actions requiring corrective action plan should be followed up on to ensure that the matter is resolved; and 3. Ensure that all uniform guidance reports are collected and reviewed timely so that a management decision letter can be issued within the time period required by federal regulations. Retain evidence of Department review of uniform guidance reports and management letters issued as a result of their review. View of Responsible Officials: Management partially concurs with the finding above Rejoinder As it relates to Bullet C above, for 3 of 3 subrecipients selected for testwork, the Department did not complete its annual fiscal monitoring review during the audit period as required by their monitoring policy
Finding 2023-005 – Allowable Costs/Cost Principles (Indirect Cost Rate) Federal Agency: Department of Health and Human Services Federal program title: Block Grants for Community Mental Health Services Assistance Listing Number: 93.958 Pass-Through Agency: Illinois Department of Human Services Pass-Through Number: 45CBB04278; 45CBB03514; 45CBB00648 Award Period: 07/01/2022 – 06/30/2023 Type of Finding: Material weakness in internal control over compliance Criteria or specific requirement: Appendix IV to Part 200—Indirect (F&A) Costs Identification and Assignment, and Rate Determination for Nonprofit Organizations - Section C. Negotiation and Approval of Indirect Cost Rates - Subsection 2. Negotiation and approval of Rates - Clauses "c:" Unless approved by the cognizant agency for indirect costs in accordance with § 200.414(g), organizations that have previously established indirect cost rates must submit a new indirect cost proposal to the cognizant agency for indirect costs within six months after the close of each fiscal year; and "g:" The results of each negotiation must be formalized in a written agreement between the cognizant agency for indirect costs and the nonprofit organization. The cognizant agency for indirect costs must make available copies of the agreement to all concerned Federal agencies. Condition: The Organization requested reimbursement for indirect costs for a twelve-month period in which its indirect cost rate had expired. Questioned Costs: None. Context: The Organization's indirect cost rate expired on June 30, 2022; however, the Organization did not become aware of this or request an extension until June 2023. In August 2023, the Cognizant Agency for indirect costs (the Agency) did provide written notice to the Organization that it could continue using its previous indirect cost rate until the Agency completed its review of the Organization's new indirect cost rate proposal and a new rate could be established. Cause: Staff turnover. Effect: Potential unallowable costs could be charged to and reimbursed by the grant. Repeat Finding: No Recommendation: Management should refine its processes and controls over indirect costs to more closely monitor whether indirect costs being allocated to a grant are based on its current federally negotiated indirect cost rate. This may include identifying the expiration date of the Organization's indirect cost rate during the grant budget preparation process and requesting an extension before the rate expires, or preparing and submitting a new indirect cost rate proposal at the earliest opportunity. Views of responsible officials: There is no disagreement with the audit finding.
2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the District’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the Schedule must: 1. List individual Federal programs by Federal agency. 2. For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. 3. Provide total Federal awards expended for each individual Federal program and the CFDA number or other identifying number when the CFDA information is not available. 4. Include the total amount provided to subrecipients from each Federal program. 5. For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. 6. Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The lack of effective controls over this compliance requirement resulted in the Schedule being understated $302,121. This was due to the Emergency Connectivity Grant and Coronavirus State Fiscal Recovery Funds being omitted from the Schedule in the amount of $193,280 and $138,836, respectively, an understatement in the Nutrition Cluster of $30,402 and an overstatement of the 21st Century Grant of $60,397. The audited Schedule has been adjusted to correct these items. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit. The Treasurer should review reported federal expenditures to ensure accuracy of amounts reported. This will help ensure the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the District’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the Schedule must: 1. List individual Federal programs by Federal agency. 2. For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. 3. Provide total Federal awards expended for each individual Federal program and the CFDA number or other identifying number when the CFDA information is not available. 4. Include the total amount provided to subrecipients from each Federal program. 5. For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. 6. Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The lack of effective controls over this compliance requirement resulted in the Schedule being understated $302,121. This was due to the Emergency Connectivity Grant and Coronavirus State Fiscal Recovery Funds being omitted from the Schedule in the amount of $193,280 and $138,836, respectively, an understatement in the Nutrition Cluster of $30,402 and an overstatement of the 21st Century Grant of $60,397. The audited Schedule has been adjusted to correct these items. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit. The Treasurer should review reported federal expenditures to ensure accuracy of amounts reported. This will help ensure the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the District’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the Schedule must: 1. List individual Federal programs by Federal agency. 2. For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. 3. Provide total Federal awards expended for each individual Federal program and the CFDA number or other identifying number when the CFDA information is not available. 4. Include the total amount provided to subrecipients from each Federal program. 5. For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. 6. Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The lack of effective controls over this compliance requirement resulted in the Schedule being understated $302,121. This was due to the Emergency Connectivity Grant and Coronavirus State Fiscal Recovery Funds being omitted from the Schedule in the amount of $193,280 and $138,836, respectively, an understatement in the Nutrition Cluster of $30,402 and an overstatement of the 21st Century Grant of $60,397. The audited Schedule has been adjusted to correct these items. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit. The Treasurer should review reported federal expenditures to ensure accuracy of amounts reported. This will help ensure the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the District’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the Schedule must: 1. List individual Federal programs by Federal agency. 2. For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. 3. Provide total Federal awards expended for each individual Federal program and the CFDA number or other identifying number when the CFDA information is not available. 4. Include the total amount provided to subrecipients from each Federal program. 5. For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. 6. Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The lack of effective controls over this compliance requirement resulted in the Schedule being understated $302,121. This was due to the Emergency Connectivity Grant and Coronavirus State Fiscal Recovery Funds being omitted from the Schedule in the amount of $193,280 and $138,836, respectively, an understatement in the Nutrition Cluster of $30,402 and an overstatement of the 21st Century Grant of $60,397. The audited Schedule has been adjusted to correct these items. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit. The Treasurer should review reported federal expenditures to ensure accuracy of amounts reported. This will help ensure the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the District’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the Schedule must: 1. List individual Federal programs by Federal agency. 2. For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. 3. Provide total Federal awards expended for each individual Federal program and the CFDA number or other identifying number when the CFDA information is not available. 4. Include the total amount provided to subrecipients from each Federal program. 5. For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. 6. Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The lack of effective controls over this compliance requirement resulted in the Schedule being understated $302,121. This was due to the Emergency Connectivity Grant and Coronavirus State Fiscal Recovery Funds being omitted from the Schedule in the amount of $193,280 and $138,836, respectively, an understatement in the Nutrition Cluster of $30,402 and an overstatement of the 21st Century Grant of $60,397. The audited Schedule has been adjusted to correct these items. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit. The Treasurer should review reported federal expenditures to ensure accuracy of amounts reported. This will help ensure the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the District’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the Schedule must: 1. List individual Federal programs by Federal agency. 2. For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. 3. Provide total Federal awards expended for each individual Federal program and the CFDA number or other identifying number when the CFDA information is not available. 4. Include the total amount provided to subrecipients from each Federal program. 5. For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. 6. Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The lack of effective controls over this compliance requirement resulted in the Schedule being understated $302,121. This was due to the Emergency Connectivity Grant and Coronavirus State Fiscal Recovery Funds being omitted from the Schedule in the amount of $193,280 and $138,836, respectively, an understatement in the Nutrition Cluster of $30,402 and an overstatement of the 21st Century Grant of $60,397. The audited Schedule has been adjusted to correct these items. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit. The Treasurer should review reported federal expenditures to ensure accuracy of amounts reported. This will help ensure the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the District’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the Schedule must: 1. List individual Federal programs by Federal agency. 2. For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. 3. Provide total Federal awards expended for each individual Federal program and the CFDA number or other identifying number when the CFDA information is not available. 4. Include the total amount provided to subrecipients from each Federal program. 5. For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. 6. Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The lack of effective controls over this compliance requirement resulted in the Schedule being understated $302,121. This was due to the Emergency Connectivity Grant and Coronavirus State Fiscal Recovery Funds being omitted from the Schedule in the amount of $193,280 and $138,836, respectively, an understatement in the Nutrition Cluster of $30,402 and an overstatement of the 21st Century Grant of $60,397. The audited Schedule has been adjusted to correct these items. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit. The Treasurer should review reported federal expenditures to ensure accuracy of amounts reported. This will help ensure the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes, 2022-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not separately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total Federal awards expended for loan or loan guarantee programs in the schedule and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2023 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Expenditures of Federal awards, which prevented the City from meeting the March 31, 2024 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes, 2022-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not separately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total Federal awards expended for loan or loan guarantee programs in the schedule and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2023 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Expenditures of Federal awards, which prevented the City from meeting the March 31, 2024 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes, 2022-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not separately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total Federal awards expended for loan or loan guarantee programs in the schedule and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2023 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Expenditures of Federal awards, which prevented the City from meeting the March 31, 2024 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes, 2022-006 Condition: Finance is responsible for preparing the schedule of expenditures of Federal awards based upon grant information obtained from the financial accounting records and other information provided by each department or agency. In many instances, the detail expenditure information in the accounting software differed from the expenditures reported by various City departments. Additionally, expenditures related to sub-recipients, subcontractors, and beneficiaries are not separately tracked in the general ledger. Criteria: In accordance with 2 CFR 200.303, Internal controls: 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. In accordance with 2 CFR 200.508, Auditee responsibilities: The auditee must: (b) Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. In accordance with 2 CFR 200.510, Financial statements: (b) Schedule of expenditures of Federal awards: the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amount of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available. For a cluster of programs, also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total Federal awards expended for loan or loan guarantee programs in the schedule and (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the non-Federal entity elected to use the 10% de minimis cost rate as covered in §200.414 Indirect (F&A) costs. Cause: The City does not maintain a centralized grant accounting function or standardized policies and procedures, including requirements to periodically submit and reconcile expenditures; instead, each department maintains its own grant information. The lack of submission of grant documents and accurate information by the various agencies and departments to Finance weakens internal controls over grant reporting and hinders the ability of Finance to accurately prepare the Schedule. Internal controls over financial reporting should be designed to prevent, detect or correct errors in a timely manner. Without adequate controls, the City cannot provide reasonable assurance that the Schedule is fairly presented. Controls have not been established by the City to ensure complete and accurate reporting for the Schedule for the 2023 fiscal year. Effect: The determination of which major programs will be audited is affected by the accuracy of the Schedule at the time of audit. Without proper internal controls over financial reporting, inaccurate reporting of the City’s financial information could occur and the City cannot provide reasonable assurance that the SEFA is fairly presented. As a result, individual program reports throughout the year could have inaccurate information. There were also significant delays in the preparation of the Schedule of Expenditures of Federal awards, which prevented the City from meeting the March 31, 2024 deadline with the Federal clearinghouse. Questioned Costs: Unknown. Recommendation: We recommend that Finance establish policies and procedures to ensure that the Federal funds are properly identified and reported accurately in the Schedule in accordance with Uniform Guidance requirements. We also recommend that individuals responsible for administering Federal assistance programs with the City receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.