Title and Financial Assistance Listing Number of Federal Program: All federal programs Type of Finding: Federal Award Finding Finding Resolution Status: Resolved Information on Universe Population Size: N/A Sample Size Information: N/A Identification of Repeat Finding and Finding Reference Number: N/A Criteria: 2 CFR 200.501 Statement of Condition: The Organization failed to timely file a single audit with the Federal Audit Clearing House. Auditor considers this to be a material weakness. Cause: The Organization did not have controls in place to identify and track federal awards and therefore, the Organization was not aware of their reporting requirement under Uniform Guidance. Effect or Potential Effect: The Organization was did not comply with Uniform Guidance requirements for federal funds expended in excess of $750,000. Auditor Non-Compliance Code: S - Internal control deficiencies Questioned Costs: $- Reportable Views of Responsible Officials: The Organization received additional, one-time COVID-19-related funding that was out of the norm for the Organization. We were not aware that it caused us to exceed the $750,000 threshold for a Uniform Guidance audit. Recommendation: The Organization should develop a process for identifying and tracking federal expenditures for all awards that are federally sourced to ensure the organization completes required compliance audits in years where federal expenditures exceed $750,000.
Finding 2021-008 Subrecipient Agreements - Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Control over Compliance Agency Department of the Treasury ALN 21.019 Program COVID-19 - Coronavirus Relief Fund Award Year FY 2021 Pass-Through Agency State of Alaska Department of Commerce, Community, and Economic Development Pass-Through Entity Identifying Number 20-CRF-024 Criteria 2 CFR 200.332 requires pass-through entities to ensure that subrecipients comply with the terms and conditions of 2 CFR 200.501 related to audit requirements. This includes ensuring that every subaward is (1) clearly identified to the subrecipient as a subaward; (2) includes the necessary information at the time of the subaward for subrecipient reporting on federal awards (2 CFR 200.332) and (3) includes requirement to follow 2 CFR 200.501 if expenditure thresholds are met. This also includes verifying that every subrecipient is audited as required by 2 CFR 200.501 if the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold. Condition During our testing of subrecipient monitoring, we noted the subrecipient agreements did not include the required federal award identification or applicability of audit requirements. No action was taken to ensure the subrecipients were audited in accordance with 2 CFR 200.501 if applicable. Cause The issuance of subrecipient agreements for these grants related to new funding streams in response to the COVID-19 pandemic. Significant amounts of funding were provided in a short period of time, and systems to distribute these monies were newly created and implemented. The standard award agreements were not reviewed in advance to ensure adherence to federal requirements. Staff were not fully trained on the informational requirements and monitoring responsibilities related to audit requirements. Effect or potential effect Subrecipients may be unaware and not in compliance with the requirements of 2 CFR Part 200. Questioned costs Not applicable. Context We tested the sole subaward agreement for the program and noted the agreement did not contain the necessary language under 2 CFR 200.332 to inform subrecipients of the applicability of 2 CFR 200, Subpart F. Identification as a repeat finding Not a repeat finding. Recommendation Management should establish policies to ensure subawards contain required federal award information. In addition, procedures should be established to monitor subrecipient compliance with audit requirements of 2 CFR 200.501. Views of responsible officials Management concurs with the finding. Management will revise policies and procedures related to subrecipient monitoring and will ensure that policies are established to ensure subawards contain the required federal award information.
Finding 2021-009 Monitoring Activities - Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Control over Compliance Agency Department of the Treasury ALN 21.019 Program COVID-19 - Coronavirus Relief Fund Award Year FY 2021 Pass-Through Agency State of Alaska Department of Commerce, Community, and Economic Development Pass-Through Entity Identifying Number 20-CRF-024 Criteria 2 CFR 200.332 requires that pass-through entities 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. 2 CFR 200.332 also requires pass-through entities to 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 2 CFR 200.501. Condition The City did not have controls in place to monitor subrecipient activities and ensure the subrecipient was audited in accordance with 2 CFR 200.501 if applicable. Cause Staff were not fully trained on the informational requirements and monitoring responsibilities related to audit requirements. Effect or potential effect The City was not in compliance with subrecipient requirements outlined in 2 CFR 200.332. Furthermore, not communicating proper compliance requirements and other information may increase the likelihood of noncompliance on the part of the subrecipient and non-fulfillment of program goals and objectives. Questioned costs Not applicable. Context We were not able to verify controls over subrecipient monitoring. The audit of the subrecipient was completed by other auditors including an audit in accordance with the Uniform Guidance requirements on December 3, 2021. The City obtained the audited reports in April 2023. Identification as a repeat finding Not a repeat finding. Recommendation Management should establish policies and procedures to monitor subrecipient compliance with audit requirements of 2 CFR 200.501. Views of responsible officials Management concurs with the finding. Management will revise policies and procedures related to subrecipient monitoring and will ensure that policies are established to ensure subawards contain the required federal a ward information.
Reference Number: 2021-014 Category of Finding: Subrecipient Monitoring Type of Finding: Material Weakness and Material Instance of Noncompliance State Administering Department: California Department of Public Health (Public Health) Assistance Listing Number: 93.323 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Award Number and Year: NU50CK000539; 2021 Criteria: Title 2 - Grants and Agreements. Subtitle A - Office of Management and Budget Guidance for Grants and Agreements. Chapter II - Office of Management and Budget Guidance. Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D - Post Federal Award Requirements. §200.303 Internal controls (2 CFR 200.303): The non-Federal entity must: (b) 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). Title 2 - Grants and Agreements. Subtitle A - Office of Management and Budget Guidance for Grants and Agreements. Chapter II - Office of Management and Budget Guidance. Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D - Post Federal Award Requirements. §200.332 Requirements for pass-through entities (2 CFR 200.332): All pass-through entities must: (c) 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). (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. (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. Condition: Public Health did not establish a formal risk assessment process over its subrecipients of federal awards to determine the frequency and extent of subrecipient monitoring to be performed. While Public Health received reimbursement invoices from subrecipients, there did not appear to be other financial or programmatic monitoring to verify subrecipents compliance with applicable requirements. In addition, Public Health did not obtain Single Audit reports from those subrecipients as required. Identification as a Repeat Finding This was not a repeat finding from the immediate prior year. Cause: Public Health failed to identify and report its federal expenditures related to its subrecipient agreement with its bona fide agent. Consequently, required subrecipient monitoring procedures were not designed nor implemented by Public Health. Effect: By not properly evaluating the risk of noncompliance, Public Health may inadvertently award grant funds to subrecipients who lack the necessary mechanisms or understanding to adhere to federal statutes. This increases the likelihood of noncompliance arising during the implementation of the grant-funded activities. Furthermore, failure to perform monitoring procedures or obtain Single Audit reports increases the risk for not properly identifying subrecipient program control weaknesses, noncompliance, and performing sufficient follow-up on any subrecipient corrective action. Questioned Costs: No questioned costs were identified. Context: Disbursements to subrecipients for the ELC program totaled $367,405,431, or 76.5% of total reported program expenditures. Recommendation: Public Health should establish and document formal procedures for conducting risk assessments of its subrecipients, including criteria for evaluating organizational capacity, financial stability, compliance history, and programmatic capabilities. Public Health should also develop and implement specific subrecipient monitoring procedures and establish a process for obtaining single audit reports from its subrecipients. Furthermore, a monitoring mechanism should be implemented to track compliance with the single audit mandate among subrecipients, including regular follow-ups and documentation of communication efforts. Views of Responsible Officials and Corrective Action Plan Management’s response is reported in “Management’s Response and Corrective Action Plan” included in a separate section at the end of this report
CFDA Number: 11.307 CFDA Title: Economic Adjustment Assistance Program Federal Agency: U.S. Department of Commerce Economic Development Administration Award Number: 04-79-07293 Type of Finding: Noncompliance Compliance Requirements: Reporting Criteria: The regulations in 2 CFR section 200.501 (a) requires a single or program-specific audit for any year in which an entity expends $750,000 or more in federal awards. Per 2 CFR Section 200.501 (c), a program specific audit may be elected when an entity expends federal awards under only one federal program and the Program does not require a financial statement audit. In addition, in accordance with 2 CFR Section 200.507 for Program Specific Audits , the audit must be submitted within the earlier of 30 calendar days after receipt of the auditor's reports or 9 months after the end of the audit period. Condition: The Foundation expended greater than $750,000 under one federal program for the year ended December 31, 2020 but did not have a program-specific audit performed. Cause: The Foundation was not aware of the audit requirement since it does not receive federal funds on a recurring basis. Effect or Potential Effect: The Foundation's ability to obtain future funding for their projects could be impacted by not complying with the reporting requirements referred to above. Questioned Costs: None Context: The occurrence of not complying with the reporting requirements referred to above appears to be an isolated instance. Repeat Finding from Prior Year: No Recommendation: The Foundation should take appropriate action to ensure that all reporting requirements are known in the future and met on all of its potential future federal programs. Views of Responsible Officials and Corrective Action Planned: Management of the Foundation concurs with the audit finding. When management discovered the requirement had not been met, they immediately contacted an independent auditor to perform the program-specific audit to satisfy the reporting requirements.
CFDA Number: 11.307 CFDA Title: Economic Adjustment Assistance Program Federal Agency: U.S. Department of Commerce Economic Development Administration Award Number: 04-79-07293 Type of Finding: Noncompliance Compliance Requirements: Reporting Criteria: The regulations in 2 CFR section 200.501 (a) requires a single or program-specific audit for any year in which an entity expends $750,000 or more in federal awards. Per 2 CFR Section 200.501 (c), a program specific audit may be elected when an entity expends federal awards under only one federal program and the Program does not require a financial statement audit. In addition, in accordance with 2 CFR Section 200.507 for Program Specific Audits , the audit must be submitted within the earlier of 30 calendar days after receipt of the auditor's reports or 9 months after the end of the audit period. Condition: The Foundation expended greater than $750,000 under one federal program for the year ended December 31, 2020 but did not have a program-specific audit performed. Cause: The Foundation was not aware of the audit requirement since it does not receive federal funds on a recurring basis. Effect or Potential Effect: The Foundation's ability to obtain future funding for their projects could be impacted by not complying with the reporting requirements referred to above. Questioned Costs: None Context: The occurrence of not complying with the reporting requirements referred to above appears to be an isolated instance. Repeat Finding from Prior Year: No Recommendation: The Foundation should take appropriate action to ensure that all reporting requirements are known in the future and met on all of its potential future federal programs. Views of Responsible Officials and Corrective Action Planned: Management of the Foundation concurs with the audit finding. When management discovered the requirement had not been met, they immediately contacted an independent auditor to perform the program-specific audit to satisfy the reporting requirements.
Finding No.: 2019-012 Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Criteria: In accordance with CFR part 200.332, a pass-through entity’s monitoring responsibilities include verification that every subrecipient is audited when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the $750,000 threshold set forth in §200.501 Audit requirements. In addition, to equally distribute subawards, CHCC should issue public publication notices for interested nonprofit organizations to apply. Condition: Of five subrecipients tested, aggregating $160,000 of a total population of $468,864, the following deficiencies were noted: 1. For five (or 100%), documentation of the monitoring procedures performed to determine whether any of the subrecipients expended $750,000 or more in federal funds and whether those that expended $750,000 or more were audited, were not provided. Total FY2019 expenditures under the subrecipient agreements were $353,864, which is a questioned costs. Finding No.: 2019-012, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Condition, continued: Test of fourteen nonpayroll expenditures pertaining to subrecipient transactions, aggregating $438,864 of a total population of $468,864, the following deficiencies were noted: 2. For fourteen (or 100%), public publication notices of subaward opportunities were not provided. Total FY2019 expenditures under the subrecipient agreements for Document Numbers 1436077, 1436266, 1456803 and 1446815 amounted to $115,000, which are for the same subrecipients, are questioned. No questioned costs are presented for the other Document Numbers as amounts are questioned at Condition 1, for which are for the same subrecipients. Finding No.: 2019-012, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Condition, continued: 3. For one (or 7%), supporting documents were not provided. No questioned costs is presented as the amount questioned at Condition 2 for Document Number 1436077 is for the same subrecipient. Cause: CHCC did not enforce recordkeeping and monitoring controls over applicable subrecipient monitoring requirements. Effect: CHCC is in noncompliance with applicable subrecipient monitoring requirements and questioned costs of $468,864 result. Identification as a Repeat Finding: Finding No. 2018-019. Recommendation: CHCC should establish and enforce required monitoring procedures and establish a recordkeeping system whereby underlying support for each transaction is processed timely and filed accordingly for easy retrieval to substantiate costs. Finding No.: 2019-012, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Views of Responsible Officials: CHCC’s Corrective Action Plan provides a detailed rationale for disagreement with the finding described in Conditions 1 to 3. Auditor Response: Condition 1 - Invoices, receipts and progress reports from prior disbursements were not provided. Condition 2 - Public publication notices of subaward opportunities were not provided. Condition 3 - We were not made aware that the transaction was voided and the corresponding reversal journal entry was also not provided. In addition, initial draft reports were provided to CHCC on 09/06/24 and 09/24/24. It was also agreed during the 09/06/24 and 10/04/24 meetings for CHCC to provide corresponding underlying accounting records to resolve the finding; however, no documentations were provided within the agreed timeline. Accordingly, finding is sustained.
Finding No.: 2019-012 Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Criteria: In accordance with CFR part 200.332, a pass-through entity’s monitoring responsibilities include verification that every subrecipient is audited when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the $750,000 threshold set forth in §200.501 Audit requirements. In addition, to equally distribute subawards, CHCC should issue public publication notices for interested nonprofit organizations to apply. Condition: Of five subrecipients tested, aggregating $160,000 of a total population of $468,864, the following deficiencies were noted: 1. For five (or 100%), documentation of the monitoring procedures performed to determine whether any of the subrecipients expended $750,000 or more in federal funds and whether those that expended $750,000 or more were audited, were not provided. Total FY2019 expenditures under the subrecipient agreements were $353,864, which is a questioned costs. Finding No.: 2019-012, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Condition, continued: Test of fourteen nonpayroll expenditures pertaining to subrecipient transactions, aggregating $438,864 of a total population of $468,864, the following deficiencies were noted: 2. For fourteen (or 100%), public publication notices of subaward opportunities were not provided. Total FY2019 expenditures under the subrecipient agreements for Document Numbers 1436077, 1436266, 1456803 and 1446815 amounted to $115,000, which are for the same subrecipients, are questioned. No questioned costs are presented for the other Document Numbers as amounts are questioned at Condition 1, for which are for the same subrecipients. Finding No.: 2019-012, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Condition, continued: 3. For one (or 7%), supporting documents were not provided. No questioned costs is presented as the amount questioned at Condition 2 for Document Number 1436077 is for the same subrecipient. Cause: CHCC did not enforce recordkeeping and monitoring controls over applicable subrecipient monitoring requirements. Effect: CHCC is in noncompliance with applicable subrecipient monitoring requirements and questioned costs of $468,864 result. Identification as a Repeat Finding: Finding No. 2018-019. Recommendation: CHCC should establish and enforce required monitoring procedures and establish a recordkeeping system whereby underlying support for each transaction is processed timely and filed accordingly for easy retrieval to substantiate costs. Finding No.: 2019-012, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Views of Responsible Officials: CHCC’s Corrective Action Plan provides a detailed rationale for disagreement with the finding described in Conditions 1 to 3. Auditor Response: Condition 1 - Invoices, receipts and progress reports from prior disbursements were not provided. Condition 2 - Public publication notices of subaward opportunities were not provided. Condition 3 - We were not made aware that the transaction was voided and the corresponding reversal journal entry was also not provided. In addition, initial draft reports were provided to CHCC on 09/06/24 and 09/24/24. It was also agreed during the 09/06/24 and 10/04/24 meetings for CHCC to provide corresponding underlying accounting records to resolve the finding; however, no documentations were provided within the agreed timeline. Accordingly, finding is sustained.
THE COUNCIL DID NOT SUBMIT THE REPORTING PACKAGE TIMELY IN ACCORDANCE WITH THE UNIFORM GUIDANCE REQUIREMENT OF SUBMITTING THE REPORTING PACKAGE WITHIN 9 MONTHS OF YEAR END. IN ADDITION, IT WAS NOTED THAT THE APR WAS FILED LATE. PER 2 CFR SECTION 200.328 AND 329, THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS. PER SECTION 200.501, THE COUNCIL MUST HAVE AN AUDIT PERFORMED WITHIN 9 MONTHS OF YEAR END. QUESTIONED COSTS NOT DETERMINED, MANAGEMENT DID NOT ENSURE THAT THAT THE AUIDT AND ALL REPORTS WERE FILED/SUBMITTED TIMELY
THE COUNCIL DID NOT SUBMIT THE REPORTING PACKAGE TIMELY IN ACCORDANCE WITH THE UNIFORM GUIDANCE REQUIREMENT OF SUBMITTING THE REPORTING PACKAGE WITHIN 9 MONTHS OF YEAR END. IN ADDITION, IT WAS NOTED THAT THE APR WAS FILED LATE. PER 2 CFR SECTION 200.328 AND 329, THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATIC REPORTING REQUIREMENTS. PER SECTION 200.501, THE COUNCIL MUST HAVE AN AUDIT PERFORMED WITHIN 9 MONTHS OF YEAR END. QUESTIONED COSTS NOT DETERMINED, MANAGEMENT DID NOT ENSURE THAT THAT THE AUIDT AND ALL REPORTS WERE FILED/SUBMITTED TIMELY