Finding No. 2024-001 Implement System-Based Tracking of Federal Expenditures Assistance Listing Number: 93.566 Program Name: Refugee and Entrant Assistance State/Replacement Designee Administered Programs Federal Agency: Department of Health and Human Services (HHS) Passed Through Entities: 1. California Department of Social Services 2. University of California, San Diego 3. California Rural Legal Assistance Foundation 4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team 5. Public Health Institute (PHI) Federal Award Numbers: ALSP22-0002-A1, ALSP23-0001, PUR00533092, ACS22-05-CAIR, 06568-AR76924 Federal Award Year: August 1, 2022 to June 30, 2026 Compliance Requirement: Activities Allowed or Unallowed Criteria: Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements. 2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger). In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended. Condition: During our review of the SEFA, we noted that CAIR-CA utilizes workbooks outside of its accounting software to track federal expenditures. The workbooks do not reconcile directly with the general ledger (GL), so management performs a separate reconciliation to support the SEFA amounts. This approach was similarly observed in the prior year's audit. Cause: The prior year audit was completed in August 2025, after the close of the fiscal year 2024. As a result, management was still in the process of implementing a system-based tracking during the year 2024. CAIR-CA’s processes for tracking federal awards are continuing to develop, as this is only the second year under Single Audit. Effect: Using manual workbooks requires additional manual effort and may make reconciliation between SEFA and GL more time-consuming, and may result in inaccurate or incomplete reporting. Questioned Cost: None Recommendation: We recommend that CAIR-CA continue enhancing its accounting processes to track federal expenditures directly within its accounting software. This could include GL tracking codes or other similar identifiers for federal programs. System based tracking would simplify SEFA preparation, improve consistency with the general ledger, and strengthen monitoring of federal expenditures. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already updated the accounting system to incorporate grant-specific tracking codes to further align with federal reporting standards. Because the organization’s first single audit in FY2023 was conducted concurrently with the FY2024 single audit, there was limited opportunity for these procedural improvements to be reflected in the FY2024 single audit testing cycle. As a result, the impact of these changes will be more fully reflected in the FY2025 single audit, which is scheduled to commence this year. As part of a layered approach to internal controls, excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Implementation date: November 20, 2025
Information on Federal Programs: 93.083 – Centers for Disease Control and Prevention: Prevention of Disease, Disability, and Death through Immunization & Control of Respiratory & Related Diseases. Criteria or Specific Requirements: 2 CFR §200.510(b) requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee’s financial statements that includes Federal awards expended during that fiscal year. 2 CFR §500.502 provides that the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. Condition: During testing of the SEFA for the year ended December 31, 2024, we noted that certain Federal program expenditures related to activities incurred in fiscal year 2023 were reported in the 2024 SEFA instead of in the 2023 SEFA. Cause: Management’s procedures for preparing and reviewing the SEFA did not include sufficient controls to ensure that expenditures are reported in the correct fiscal year. Effect: The SEFA for the year ended December 31, 2023 was incomplete, and the SEFA for the year ended December 31, 2024 includes expenditures that related to activities incurred in fiscal year 2023. Although the expenditures were allowable costs of the Federal program, the timing misstatement affects the accuracy of SEFA presentation and could affect the usefulness of SEFA information to Federal agencies and pass-through entities in their monitoring and oversight. The error did not impact the major program selection process for 2023 or 2024.Perspective: This issue was identified during our testing of the SEFA for the year ended December 31, 2024, when we noted that ATS reported $114,984 of Federal award expenditures in 2024 that related to activities incurred in fiscal year 2023. These expenditures should have been reported in the SEFA for year ended December 31, 2023. Questioned Costs: None. Identification as a Repeat Finding: Not applicable. Recommendation: ATS should implement formal procedures for compiling the SEFA, including (1) reconciling SEFA amounts to the general ledger and other supporting records, (2) performing a year-end review to confirm that expenditures are reported in the correct fiscal year in accordance with 2 CFR §200.502 and 2 CFR §200.510(b), and (3) documenting supervisory review of the SEFA prior to finalization.
Reporting – Incomplete Schedule of Expenditures of Federal Awards Identification as a Repeat Finding: Not a repeat finding Federal Awards: 21.027 - Coronavirus State and Local Fiscal REcovery Funds Finding: The Authority did not properly identify proceeds received under a pass-through loan program as including federal award funds under the U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds program, and therefore the loan was improperly excluded from the schedule of expenditures of federal awards (SEFA). Sample Size and Population: Sampling was not applicable to this finding. Questioned Costs: None Criteria: The Authority is required to report all federal awards expended during the audit period on the SEFA. For federal loan programs, federal awards expended include the value of new loans received during the audit period, and the SEFA notes must identify outstanding loan balances at the end of the audit period. 2 CFR § 200.502(a)(3), 2 CFR § 200.502(b)(1), and 2 CFR § 200.510(b)(5). Condition: The Authority’s originally issued 2024 SEFA omitted $2,477,915 of federal expenditures related to a pass-through loan from the Washington State Department of Commerce. The loan included federal funds from the U.S. Department of the Treasury’s Coronavirus State and Local Fiscal Recovery Funds program, Assistance Listing 21.027. The entire federal portion of the loan was drawn during the year ended December 31, 2024, and the outstanding balance of the federal portion of the loan was $2,477,915 at December 31, 2024 and $0 at December 31, 2023. The omission was identified after the original 2024 Single Audit report had been issued Cause: The Authority did not have an effective process to ensure that all departments communicated federal award and loan information to the finance department for SEFA reporting. Effect: The originally issued SEFA was materially understated by $2,477,915, and the SEFA notes omitted the $2,477,915 outstanding federal loan balance at December 31, 2024. The omission affected the major program determination because Assistance Listing 21.027 was not included in the original SEFA or original major program selection. As a result, the originally issued Single Audit reporting package did not include the revised SEFA amounts, did not identify ALN 21.027 as a major program, and did not include auditor testing and reporting over the ALN 21.027 major program. Recommendations: Management should implement procedures to ensure all grant agreements, loan agreements, pass-through award notices, and related amendments are reviewed by the finance department to determine whether they include federal funds. Management should also require communication between project management and finance personnel, perform a year-end reconciliation of loan draws and outstanding balances to the SEFA, and document review of the SEFA and related notes before issuance. Management Response: Management response is reported in the “Corrective Action Plan” at the end of this report. Contact Person: Lowel Krueger, Executive Director
2024-001 - SEFA REPORTING Federal Program Information: Federal Agency and Program Name - National Endowment for the Humanities Promotion of the Humanities Federal/State Partnership Grant Number: SO-289836-23 Federal Assistance Listing Number 45.129 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.510(b) states that “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 2 CFR 200.502.” Condition: The Council’s internal controls are not adequate to ensure the Schedule of Expenditures of Federal Awards (SEFA) accurately reports Federal assistance. The Council’s fiscal year 2024 SEFA for the Promotion of the Humanities Federal/State Partnership program included expenditures from other fiscal years. Questioned Costs: Not applicable. Context: Total federal expenditures for the Promotion of the Humanities Federal/State Partnership program were $902,649 for the year ended October 31, 2024. Cause: The Council does not have adequate internal controls in place to ensure the accuracy of the SEFA. Effect: The Council is not reporting accurate financial information in its SEFA. Identification as a Repeat Finding: Prior Year Finding 2023-004 Recommendation: We recommend that the Council implement controls over financial reporting, including the SEFA, to ensure accuracy of financial data. Views of Responsible Officials: Management acknowledges the finding. See corrective action plan.
2024-001 - SEFA REPORTING Federal Program Information: Federal Agency and Program Name - National Endowment for the Humanities Promotion of the Humanities Federal/State Partnership Grant Number: SO-289836-23 Federal Assistance Listing Number 45.129 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.510(b) states that “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 2 CFR 200.502.” Condition: The Council’s internal controls are not adequate to ensure the Schedule of Expenditures of Federal Awards (SEFA) accurately reports Federal assistance. The Council’s fiscal year 2024 SEFA for the Promotion of the Humanities Federal/State Partnership program included expenditures from other fiscal years. Questioned Costs: Not applicable. Context: Total federal expenditures for the Promotion of the Humanities Federal/State Partnership program were $902,649 for the year ended October 31, 2024. Cause: The Council does not have adequate internal controls in place to ensure the accuracy of the SEFA. Effect: The Council is not reporting accurate financial information in its SEFA. Identification as a Repeat Finding: Prior Year Finding 2023-004 Recommendation: We recommend that the Council implement controls over financial reporting, including the SEFA, to ensure accuracy of financial data. Views of Responsible Officials: Management acknowledges the finding. See corrective action plan.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Assistance Listing, Federal Agency, and Program Name - 66.818, U.S. Environmental Protection Agency, Brownfields Assessment and Cleanup Cooperative Agreements; 21.027, U.S. Department of the Treasury, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year - ALN 21.027 SLFRP0127 Pass through Entity - ALN 21.027 - State of Michigan Finding Type - Material weakness Repeat Finding - Yes 2023-002 Criteria - The Single Audit Act and Uniform Guidance require a nonfederal entity that expends $750,000 or more of federal awards in a fiscal year to have a single or program-specific audit. 2 CFR §200.508 (b) indicates that the auditee must prepare financial statements, including the schedule of expenditures of federal awards in accordance with 2 CFR §200.510. Additionally, 2 CFR §200.502 describes the basis for determining the timing of when federal awards are deemed expended and, therefore, reportable on the schedule. Condition - The schedule of expenditures of federal awards (SEFA) was not accurate. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year ended September 30, 2024, the City expended approximately $2,831,000 of federal funding. The initial draft of the SEFA included the following inaccuracies: ALN 66.818 - The expenditures reported on the SEFA were understated by $148,474. ALN 21.027 - The expenditures reported on the SEFA were overstated by $2,078,221. The SEFA was also ovestated by $116,625 related to a non federal program. The errors noted above have been corrected on the SEFA as of September 30, 2024. Cause and Effect - Controls in place did not ensure the SEFA was complete and accurate for the fiscal period under audit. The errors resulted in the overstatement of federal expenditures. Recommendation - We recommend the City implement a process to ensure that the SEFA is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - The City will review its process for identifying and communicating federal grant expenditures to its auditors.
Assistance Listing, Federal Agency, and Program Name - 66.818, U.S. Environmental Protection Agency, Brownfields Assessment and Cleanup Cooperative Agreements; 21.027, U.S. Department of the Treasury, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year - ALN 21.027 SLFRP0127 Pass through Entity - ALN 21.027 - State of Michigan Finding Type - Material weakness Repeat Finding - Yes 2023-002 Criteria - The Single Audit Act and Uniform Guidance require a nonfederal entity that expends $750,000 or more of federal awards in a fiscal year to have a single or program-specific audit. 2 CFR §200.508 (b) indicates that the auditee must prepare financial statements, including the schedule of expenditures of federal awards in accordance with 2 CFR §200.510. Additionally, 2 CFR §200.502 describes the basis for determining the timing of when federal awards are deemed expended and, therefore, reportable on the schedule. Condition - The schedule of expenditures of federal awards (SEFA) was not accurate. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year ended September 30, 2024, the City expended approximately $2,831,000 of federal funding. The initial draft of the SEFA included the following inaccuracies: ALN 66.818 - The expenditures reported on the SEFA were understated by $148,474. ALN 21.027 - The expenditures reported on the SEFA were overstated by $2,078,221. The SEFA was also ovestated by $116,625 related to a non federal program. The errors noted above have been corrected on the SEFA as of September 30, 2024. Cause and Effect - Controls in place did not ensure the SEFA was complete and accurate for the fiscal period under audit. The errors resulted in the overstatement of federal expenditures. Recommendation - We recommend the City implement a process to ensure that the SEFA is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - The City will review its process for identifying and communicating federal grant expenditures to its auditors.
--Type of Finding: Material weakness in internal control over compliance --Criteria: The Uniform Guidance (2 CFR Part 200, subpart F) states it is the responsibility of the Organization’s management to ensure internal controls are properly designed and implemented in order to identify federal awards and expenditures of federal awards and to prepare a schedule of expenditures of federal awards (SEFA) that includes the total federal awards expended, as determined in accordance with § 200.502. --Condition and Context: While performing audit procedures, we identified two federal subawards that were not previously identified as such by management and had not been included on the SEFA for the year ended September 30, 2024 as originally presented for audit. The SEFA was subsequently corrected prior to issuance of the audit. The original SEFA was materially misstated due to the exclusion of expenditures under the federal subawards totaling $379,232. --Cause of Condition: Management failed to identify the agreements as federal subawards and the related expenditures for inclusion on the SEFA. --Effect of Condition: Failure to accurately identify all federal awards could cause the SEFA to be materially misstated and the performance of an insufficient major federal award programs audit. --Questioned Costs: None. --Repeat Finding: No. --Recommendation: We recommend the organization revisit its policies and procedures surrounding management’s review of grant and other contractual agreements to ensure all federal assistance, including subawards, are properly identified as such at the time the agreements are signed or received, and are properly included on the SEFA. --Views of Responsible Officials: See attached Corrective Action Plan.
--Type of Finding: Material weakness in internal control over compliance --Criteria: The Uniform Guidance (2 CFR Part 200, subpart F) states it is the responsibility of the Organization’s management to ensure internal controls are properly designed and implemented in order to identify federal awards and expenditures of federal awards and to prepare a schedule of expenditures of federal awards (SEFA) that includes the total federal awards expended, as determined in accordance with § 200.502. --Condition and Context: While performing audit procedures, we identified two federal subawards that were not previously identified as such by management and had not been included on the SEFA for the year ended September 30, 2024 as originally presented for audit. The SEFA was subsequently corrected prior to issuance of the audit. The original SEFA was materially misstated due to the exclusion of expenditures under the federal subawards totaling $379,232. --Cause of Condition: Management failed to identify the agreements as federal subawards and the related expenditures for inclusion on the SEFA. --Effect of Condition: Failure to accurately identify all federal awards could cause the SEFA to be materially misstated and the performance of an insufficient major federal award programs audit. --Questioned Costs: None. --Repeat Finding: No. --Recommendation: We recommend the organization revisit its policies and procedures surrounding management’s review of grant and other contractual agreements to ensure all federal assistance, including subawards, are properly identified as such at the time the agreements are signed or received, and are properly included on the SEFA. --Views of Responsible Officials: See attached Corrective Action Plan.
--Type of Finding: Material weakness in internal control over compliance --Criteria: The Uniform Guidance (2 CFR Part 200, subpart F) states it is the responsibility of the Organization’s management to ensure internal controls are properly designed and implemented in order to identify federal awards and expenditures of federal awards and to prepare a schedule of expenditures of federal awards (SEFA) that includes the total federal awards expended, as determined in accordance with § 200.502. --Condition and Context: While performing audit procedures, we identified two federal subawards that were not previously identified as such by management and had not been included on the SEFA for the year ended September 30, 2024 as originally presented for audit. The SEFA was subsequently corrected prior to issuance of the audit. The original SEFA was materially misstated due to the exclusion of expenditures under the federal subawards totaling $379,232. --Cause of Condition: Management failed to identify the agreements as federal subawards and the related expenditures for inclusion on the SEFA. --Effect of Condition: Failure to accurately identify all federal awards could cause the SEFA to be materially misstated and the performance of an insufficient major federal award programs audit. --Questioned Costs: None. --Repeat Finding: No. --Recommendation: We recommend the organization revisit its policies and procedures surrounding management’s review of grant and other contractual agreements to ensure all federal assistance, including subawards, are properly identified as such at the time the agreements are signed or received, and are properly included on the SEFA. --Views of Responsible Officials: See attached Corrective Action Plan.
--Type of Finding: Material weakness in internal control over compliance --Criteria: The Uniform Guidance (2 CFR Part 200, subpart F) states it is the responsibility of the Organization’s management to ensure internal controls are properly designed and implemented in order to identify federal awards and expenditures of federal awards and to prepare a schedule of expenditures of federal awards (SEFA) that includes the total federal awards expended, as determined in accordance with § 200.502. --Condition and Context: While performing audit procedures, we identified two federal subawards that were not previously identified as such by management and had not been included on the SEFA for the year ended September 30, 2024 as originally presented for audit. The SEFA was subsequently corrected prior to issuance of the audit. The original SEFA was materially misstated due to the exclusion of expenditures under the federal subawards totaling $379,232. --Cause of Condition: Management failed to identify the agreements as federal subawards and the related expenditures for inclusion on the SEFA. --Effect of Condition: Failure to accurately identify all federal awards could cause the SEFA to be materially misstated and the performance of an insufficient major federal award programs audit. --Questioned Costs: None. --Repeat Finding: No. --Recommendation: We recommend the organization revisit its policies and procedures surrounding management’s review of grant and other contractual agreements to ensure all federal assistance, including subawards, are properly identified as such at the time the agreements are signed or received, and are properly included on the SEFA. --Views of Responsible Officials: See attached Corrective Action Plan.
--Type of Finding: Material weakness in internal control over compliance --Criteria: The Uniform Guidance (2 CFR Part 200, subpart F) states it is the responsibility of the Organization’s management to ensure internal controls are properly designed and implemented in order to identify federal awards and expenditures of federal awards and to prepare a schedule of expenditures of federal awards (SEFA) that includes the total federal awards expended, as determined in accordance with § 200.502. --Condition and Context: While performing audit procedures, we identified two federal subawards that were not previously identified as such by management and had not been included on the SEFA for the year ended September 30, 2024 as originally presented for audit. The SEFA was subsequently corrected prior to issuance of the audit. The original SEFA was materially misstated due to the exclusion of expenditures under the federal subawards totaling $379,232. --Cause of Condition: Management failed to identify the agreements as federal subawards and the related expenditures for inclusion on the SEFA. --Effect of Condition: Failure to accurately identify all federal awards could cause the SEFA to be materially misstated and the performance of an insufficient major federal award programs audit. --Questioned Costs: None. --Repeat Finding: No. --Recommendation: We recommend the organization revisit its policies and procedures surrounding management’s review of grant and other contractual agreements to ensure all federal assistance, including subawards, are properly identified as such at the time the agreements are signed or received, and are properly included on the SEFA. --Views of Responsible Officials: See attached Corrective Action Plan.
Findings and Questioned Costs Relating to Federal Awards 2024 001 SEFA Control Deficiency U.S. Department of Treasury Community Development Financial Institutions Program (ALN 21.033) Statistically Valid Sample: No, and it was not intended to be. Prior Year Finding: Not a repeat finding. Finding Type: Significant deficiency Criteria CFR 200.502(a) requires expenditures be recorded in the period they occur. Additionally, 2 CFR 200.303(a) states that 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 and Context During our test work over the Schedule of Expenditures of Federal Awards (SEFA), we noted the Organization incorrectly reported expenditures, in the amount of $693,023, incurred in the fiscal year ended September 30, 2023 on the 2024 SEFA. CFR 200.502(a) requires expenditures be recorded on the SEFA in the period they occur. The 2023 expenditures were incurred during the performance period of the grant and were for activities allowed under the grant, therefore there were no questioned costs or noncompliance related to the expenditures. The Organization’s internal controls were not designed to detect that the expenditures were not timely reported on the SEFA. Cause The significant deficiency arose primarily from a misunderstanding and misapplication of SEFA preparation rules in accordance with CFR 200.502(a), specifically regarding the timing of recording expenditures. Effect Failure to properly report expenditures on the SEFA can lead to a missed or incorrect major program determination. Questioned Costs None. Recommendation We recommend that the Organization strengthen its internal controls to ensure all expenditures are reported on the SEFA in the period incurred to comply with the requirements of CFR 200.502(a). Views of Responsible Officials As noted by our auditor, the submitted expenditures were allowable under the grant. The condition exists such that these expenditures were included within the current period SEFA report because that is when they were determined to be applicable, rather than the period when they were actually incurred (the prior period SEFA report). Going forward, management will ensure to report expenditures in the period they were incurred rather than the period they were applied.
2024-003 ─ Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) U.S. Department of Transportation – Federal Transit Cluster (ALN No. 20.507) Federal award year 2023 Criteria: In accordance with 2 CFR 200.510(b), the auditee must 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 2 CFR 200.502. 2 CFR Section 200.502(a) states that the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations and the terms and conditions of federal awards, such as expenditure/expense transactions associated with grant awards. Condition: We noted that the Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) provided to the auditors for the fiscal year ended September 30, 2024 included $56,503,870 of federal expenditures for the Federal Transit Cluster, assistance listing number 20.507, that should have been included in the Schedule for the fiscal year ended September 30, 2023. The County executed an ARPA transportation grant in September 2023 for which prior year eligible incurred costs were applied, however, these expenditures were not reported on the County’s Schedule until FY 2024. The Schedule for fiscal year ended September 30, 2023 was reissued to include the $56,503,870 and the expenditures were removed from the Schedule for the fiscal year ended September 30, 2024. Context: The finding is considered isolated in nature to the federal program in question. Effect: Improper reporting of federal expenditures resulted in a material error on the Schedule. Identification as a repeat finding, if applicable: Yes (2023-006) Cause: The department directly administering this grant did not realize they had to immediately recognize the expenditures associated with the grant at the time of grant award when the decision was made to apply prior eligible incurred costs. The transaction was not recorded until the reimbursement request was submitted in fiscal year 2024. Recommendation: Grant activities including general ledger activity should be reconciled by the departments managing the programs and the information communicated timely to the Office of Financial Management and Budget (OFMB). Depending on the nature and size of the grant programs these reconciliations could occur, monthly, quarterly or yearly, depending on what is most efficient in each individual situation. Also additional training could be provided to help enhance the understanding of grant personnel around some of the important nuances of revenue and expenditure recognition criteria the County must comply with in accordance with generally accepted accounting principles so they provide OFMB with sufficient information to prepare the end of year Schedule or so they can ask questions of OFMB and County Finance and seek assistance for any matters they are unsure of how to process.
2024-003 ─ Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) U.S. Department of Transportation – Federal Transit Cluster (ALN No. 20.507) Federal award year 2023 Criteria: In accordance with 2 CFR 200.510(b), the auditee must 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 2 CFR 200.502. 2 CFR Section 200.502(a) states that the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations and the terms and conditions of federal awards, such as expenditure/expense transactions associated with grant awards. Condition: We noted that the Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) provided to the auditors for the fiscal year ended September 30, 2024 included $56,503,870 of federal expenditures for the Federal Transit Cluster, assistance listing number 20.507, that should have been included in the Schedule for the fiscal year ended September 30, 2023. The County executed an ARPA transportation grant in September 2023 for which prior year eligible incurred costs were applied, however, these expenditures were not reported on the County’s Schedule until FY 2024. The Schedule for fiscal year ended September 30, 2023 was reissued to include the $56,503,870 and the expenditures were removed from the Schedule for the fiscal year ended September 30, 2024. Context: The finding is considered isolated in nature to the federal program in question. Effect: Improper reporting of federal expenditures resulted in a material error on the Schedule. Identification as a repeat finding, if applicable: Yes (2023-006) Cause: The department directly administering this grant did not realize they had to immediately recognize the expenditures associated with the grant at the time of grant award when the decision was made to apply prior eligible incurred costs. The transaction was not recorded until the reimbursement request was submitted in fiscal year 2024. Recommendation: Grant activities including general ledger activity should be reconciled by the departments managing the programs and the information communicated timely to the Office of Financial Management and Budget (OFMB). Depending on the nature and size of the grant programs these reconciliations could occur, monthly, quarterly or yearly, depending on what is most efficient in each individual situation. Also additional training could be provided to help enhance the understanding of grant personnel around some of the important nuances of revenue and expenditure recognition criteria the County must comply with in accordance with generally accepted accounting principles so they provide OFMB with sufficient information to prepare the end of year Schedule or so they can ask questions of OFMB and County Finance and seek assistance for any matters they are unsure of how to process.
2024-003 ─ Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) U.S. Department of Transportation – Federal Transit Cluster (ALN No. 20.507) Federal award year 2023 Criteria: In accordance with 2 CFR 200.510(b), the auditee must 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 2 CFR 200.502. 2 CFR Section 200.502(a) states that the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations and the terms and conditions of federal awards, such as expenditure/expense transactions associated with grant awards. Condition: We noted that the Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) provided to the auditors for the fiscal year ended September 30, 2024 included $56,503,870 of federal expenditures for the Federal Transit Cluster, assistance listing number 20.507, that should have been included in the Schedule for the fiscal year ended September 30, 2023. The County executed an ARPA transportation grant in September 2023 for which prior year eligible incurred costs were applied, however, these expenditures were not reported on the County’s Schedule until FY 2024. The Schedule for fiscal year ended September 30, 2023 was reissued to include the $56,503,870 and the expenditures were removed from the Schedule for the fiscal year ended September 30, 2024. Context: The finding is considered isolated in nature to the federal program in question. Effect: Improper reporting of federal expenditures resulted in a material error on the Schedule. Identification as a repeat finding, if applicable: Yes (2023-006) Cause: The department directly administering this grant did not realize they had to immediately recognize the expenditures associated with the grant at the time of grant award when the decision was made to apply prior eligible incurred costs. The transaction was not recorded until the reimbursement request was submitted in fiscal year 2024. Recommendation: Grant activities including general ledger activity should be reconciled by the departments managing the programs and the information communicated timely to the Office of Financial Management and Budget (OFMB). Depending on the nature and size of the grant programs these reconciliations could occur, monthly, quarterly or yearly, depending on what is most efficient in each individual situation. Also additional training could be provided to help enhance the understanding of grant personnel around some of the important nuances of revenue and expenditure recognition criteria the County must comply with in accordance with generally accepted accounting principles so they provide OFMB with sufficient information to prepare the end of year Schedule or so they can ask questions of OFMB and County Finance and seek assistance for any matters they are unsure of how to process.
2024-003 ─ Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) U.S. Department of Transportation – Federal Transit Cluster (ALN No. 20.507) Federal award year 2023 Criteria: In accordance with 2 CFR 200.510(b), the auditee must 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 2 CFR 200.502. 2 CFR Section 200.502(a) states that the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations and the terms and conditions of federal awards, such as expenditure/expense transactions associated with grant awards. Condition: We noted that the Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) provided to the auditors for the fiscal year ended September 30, 2024 included $56,503,870 of federal expenditures for the Federal Transit Cluster, assistance listing number 20.507, that should have been included in the Schedule for the fiscal year ended September 30, 2023. The County executed an ARPA transportation grant in September 2023 for which prior year eligible incurred costs were applied, however, these expenditures were not reported on the County’s Schedule until FY 2024. The Schedule for fiscal year ended September 30, 2023 was reissued to include the $56,503,870 and the expenditures were removed from the Schedule for the fiscal year ended September 30, 2024. Context: The finding is considered isolated in nature to the federal program in question. Effect: Improper reporting of federal expenditures resulted in a material error on the Schedule. Identification as a repeat finding, if applicable: Yes (2023-006) Cause: The department directly administering this grant did not realize they had to immediately recognize the expenditures associated with the grant at the time of grant award when the decision was made to apply prior eligible incurred costs. The transaction was not recorded until the reimbursement request was submitted in fiscal year 2024. Recommendation: Grant activities including general ledger activity should be reconciled by the departments managing the programs and the information communicated timely to the Office of Financial Management and Budget (OFMB). Depending on the nature and size of the grant programs these reconciliations could occur, monthly, quarterly or yearly, depending on what is most efficient in each individual situation. Also additional training could be provided to help enhance the understanding of grant personnel around some of the important nuances of revenue and expenditure recognition criteria the County must comply with in accordance with generally accepted accounting principles so they provide OFMB with sufficient information to prepare the end of year Schedule or so they can ask questions of OFMB and County Finance and seek assistance for any matters they are unsure of how to process.
2024-003 ─ Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) U.S. Department of Transportation – Federal Transit Cluster (ALN No. 20.507) Federal award year 2023 Criteria: In accordance with 2 CFR 200.510(b), the auditee must 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 2 CFR 200.502. 2 CFR Section 200.502(a) states that the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations and the terms and conditions of federal awards, such as expenditure/expense transactions associated with grant awards. Condition: We noted that the Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) provided to the auditors for the fiscal year ended September 30, 2024 included $56,503,870 of federal expenditures for the Federal Transit Cluster, assistance listing number 20.507, that should have been included in the Schedule for the fiscal year ended September 30, 2023. The County executed an ARPA transportation grant in September 2023 for which prior year eligible incurred costs were applied, however, these expenditures were not reported on the County’s Schedule until FY 2024. The Schedule for fiscal year ended September 30, 2023 was reissued to include the $56,503,870 and the expenditures were removed from the Schedule for the fiscal year ended September 30, 2024. Context: The finding is considered isolated in nature to the federal program in question. Effect: Improper reporting of federal expenditures resulted in a material error on the Schedule. Identification as a repeat finding, if applicable: Yes (2023-006) Cause: The department directly administering this grant did not realize they had to immediately recognize the expenditures associated with the grant at the time of grant award when the decision was made to apply prior eligible incurred costs. The transaction was not recorded until the reimbursement request was submitted in fiscal year 2024. Recommendation: Grant activities including general ledger activity should be reconciled by the departments managing the programs and the information communicated timely to the Office of Financial Management and Budget (OFMB). Depending on the nature and size of the grant programs these reconciliations could occur, monthly, quarterly or yearly, depending on what is most efficient in each individual situation. Also additional training could be provided to help enhance the understanding of grant personnel around some of the important nuances of revenue and expenditure recognition criteria the County must comply with in accordance with generally accepted accounting principles so they provide OFMB with sufficient information to prepare the end of year Schedule or so they can ask questions of OFMB and County Finance and seek assistance for any matters they are unsure of how to process.
2024-003 ─ Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) U.S. Department of Transportation – Federal Transit Cluster (ALN No. 20.507) Federal award year 2023 Criteria: In accordance with 2 CFR 200.510(b), the auditee must 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 2 CFR 200.502. 2 CFR Section 200.502(a) states that the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations and the terms and conditions of federal awards, such as expenditure/expense transactions associated with grant awards. Condition: We noted that the Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) provided to the auditors for the fiscal year ended September 30, 2024 included $56,503,870 of federal expenditures for the Federal Transit Cluster, assistance listing number 20.507, that should have been included in the Schedule for the fiscal year ended September 30, 2023. The County executed an ARPA transportation grant in September 2023 for which prior year eligible incurred costs were applied, however, these expenditures were not reported on the County’s Schedule until FY 2024. The Schedule for fiscal year ended September 30, 2023 was reissued to include the $56,503,870 and the expenditures were removed from the Schedule for the fiscal year ended September 30, 2024. Context: The finding is considered isolated in nature to the federal program in question. Effect: Improper reporting of federal expenditures resulted in a material error on the Schedule. Identification as a repeat finding, if applicable: Yes (2023-006) Cause: The department directly administering this grant did not realize they had to immediately recognize the expenditures associated with the grant at the time of grant award when the decision was made to apply prior eligible incurred costs. The transaction was not recorded until the reimbursement request was submitted in fiscal year 2024. Recommendation: Grant activities including general ledger activity should be reconciled by the departments managing the programs and the information communicated timely to the Office of Financial Management and Budget (OFMB). Depending on the nature and size of the grant programs these reconciliations could occur, monthly, quarterly or yearly, depending on what is most efficient in each individual situation. Also additional training could be provided to help enhance the understanding of grant personnel around some of the important nuances of revenue and expenditure recognition criteria the County must comply with in accordance with generally accepted accounting principles so they provide OFMB with sufficient information to prepare the end of year Schedule or so they can ask questions of OFMB and County Finance and seek assistance for any matters they are unsure of how to process.
2024-003 ─ Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) U.S. Department of Transportation – Federal Transit Cluster (ALN No. 20.507) Federal award year 2023 Criteria: In accordance with 2 CFR 200.510(b), the auditee must 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 2 CFR 200.502. 2 CFR Section 200.502(a) states that the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations and the terms and conditions of federal awards, such as expenditure/expense transactions associated with grant awards. Condition: We noted that the Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) provided to the auditors for the fiscal year ended September 30, 2024 included $56,503,870 of federal expenditures for the Federal Transit Cluster, assistance listing number 20.507, that should have been included in the Schedule for the fiscal year ended September 30, 2023. The County executed an ARPA transportation grant in September 2023 for which prior year eligible incurred costs were applied, however, these expenditures were not reported on the County’s Schedule until FY 2024. The Schedule for fiscal year ended September 30, 2023 was reissued to include the $56,503,870 and the expenditures were removed from the Schedule for the fiscal year ended September 30, 2024. Context: The finding is considered isolated in nature to the federal program in question. Effect: Improper reporting of federal expenditures resulted in a material error on the Schedule. Identification as a repeat finding, if applicable: Yes (2023-006) Cause: The department directly administering this grant did not realize they had to immediately recognize the expenditures associated with the grant at the time of grant award when the decision was made to apply prior eligible incurred costs. The transaction was not recorded until the reimbursement request was submitted in fiscal year 2024. Recommendation: Grant activities including general ledger activity should be reconciled by the departments managing the programs and the information communicated timely to the Office of Financial Management and Budget (OFMB). Depending on the nature and size of the grant programs these reconciliations could occur, monthly, quarterly or yearly, depending on what is most efficient in each individual situation. Also additional training could be provided to help enhance the understanding of grant personnel around some of the important nuances of revenue and expenditure recognition criteria the County must comply with in accordance with generally accepted accounting principles so they provide OFMB with sufficient information to prepare the end of year Schedule or so they can ask questions of OFMB and County Finance and seek assistance for any matters they are unsure of how to process.
2024-003: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Finding Type: Material Weakness in Internal Controls and Noncompliance (Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Reporting) Federal Program: U.S. Department of Treasury – Local Assistance and Tribal Consistency Fund (AL #21.032) Criteria: The Code of Federal Regulations (CFR) Section 200.303(b) requires non-Federal entities to 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 terms and conditions of the Federal award. CFR Section 200.502(a) states that the determination of when a Federal award is expended should be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as expenditure/expense transactions associated with grant awards. The County reports expenditures on the SEFA when the expenditure has been incurred, or on the accrual basis of accounting, in accordance with generally accepted accounting principles. CFR Section 200.510(b) requires the auditee to prepare a SEFA for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section 200.502(a), as stated above, and must reconcile amounts reported in the SEFA to the amounts reported in the auditee’s financial statements. Condition: The SEFA was not appropriately reconciled to federal grant revenues and expenditures recorded in the financial statements. Changes were made during the closing process and during the completion of the single audit to properly report expenditures on the SEFA. Closing procedures should be in place to reconcile grant expenditures incurred at year-end, confirm the amount as eligible with the grantor, claim the grant revenues on a timely basis, reconcile the claim to the general ledger, and ensure the expenditures that will be claimed under federal awards are properly reported on the SEFA and audited financial statements prior to the start of the single audit. If expenditures reported on the SEFA are misstated, the County could fail to have a program appropriately identified as a major program and tested as a major program during the single audit. Failure to have a program audited during the single audit would result in noncompliance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Cause: Closing procedures were not in place and management did not effectively communicate with County departments responsible for administering federal awards to identify all federal grant related activity. Effect: County personnel were unable to provide a complete SEFA in the appropriate format prior to the start of the annual financial statement audit and were uncertain if a single audit was required. The SEFA required material adjustments to include all federal expenditures prior to the beginning of the single audit. Questioned Costs: No costs have been questioned as a result of this finding. Recommendation: We recommend that management meet with department heads throughout the year and during the closing process to identify all expenditures under federal awards. Training should be provided to all staff to make sure they are aware of the importance of accurately reconciling and claiming grant expenditures on a timely basis and providing the information to management for inclusion on the SEFA. Views of Responsible Officials: The County will work to improve closing processes and communications with various departments to ensure the SEFA is complete and accurate.
Finding Number: 2024-030 Prior Year Finding Number: 2023-035 Compliance Requirement: Reporting Program: U.S. Department of Health and Human Services Opioid STR ALN: 93.788 Award #: Various Award Year: 09/30/2020 – 09/29/2024 Government Department/Agency: Department of Behavioral Health (DBH) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Federal Financial Report (FFR) Controls over Reporting Compliance: 2 CFR 200.333 requires that financial records, supporting documents, statistical records, and all other non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the federal awarding agency or pass-through entity in the case of a subrecipient. Performance Progress Report (PPR) Underlying Data: The audit objective for the Reporting compliance requirement stated in the 2 CFR Part 200, appendix XI Compliance Supplement is as follows: Determine whether required reports for Federal awards include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. Schedule of Expenditures of Federal Awards (SEFA) Reporting Compliance: Requirements, Cost Principles, and Audit Requirements, section 200.510(b) states 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. 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. Condition – During our testing of the reporting compliance requirement, we noted the following: • FFR Controls over Reporting Compliance: DBH’s control over compliance for financial reporting is as follows: “All reports are reviewed by the Accounting Officer or Agency Fiscal Officer prior to submission to the Federal government. DBH Program and Fiscal Services staff review programmatic and financial reports.” We noted DBH did not timely review and approve the annual Financial Reporting Report (FFR or SF-425) prior to submission to the Federal government. Total population is one (1) report and sample selected is one (1). • PPR Reporting Compliance: We noted DBH did not have documentation for the information, as well as the source of the information, it used in the Opioid STR’s Performance Progress Report. Information as reported in the reports was unsupported as management did not retain the underlying data. Total population is two (2) reports and sample selected is one (1). • SEFA Reporting Compliance: During our testing for the SEFA, we noted that DBH incorrectly reported the value of subrecipient expenditures included within the subrecipient expenditure column. For the year ended September 30, 2024, DBH incurred $12.0 million in subrecipient expenditures for this program and incorrectly reported that there were no subrecipient expenditures on the initial SEFA. While the subrecipient expenditures amount was not accurate, the total expenditures amount was accurately reported. The error in the subrecipient expenditures amount was subsequently identified and corrected as a result of the audit process. Questioned Costs – None. Context – This is a condition identified per review of DBH’s compliance with specified reporting requirements using a statistically valid sample. Effect – Without proper internal controls and policies and procedures in place to ensure that correct amounts were reported and were properly reviewed as it relates to the Opioid STR program: • FFR Controls over Reporting Compliance: There is an increased risk of errors occurring and being undetected, or errors being present in reports if no review and approval occurred. • PPR Reporting Compliance: DBH cannot be assured that it reported complete and accurate information to enable the Substance Abuse and Mental Health Services Administration (SAMHSA), an operating division of the Department of Health and Human Services (HHS), to assess the outcomes of the State’s use of Opioid program funding. • SEFA Reporting Compliance: The effect of the condition is that the SEFA was not accurately prepared. Cause – Management did not have proper internal controls and policies and procedures in place to ensure that the amounts on the FFR and SEFA were properly reported, and the reports were properly reviewed and approved. Recommendation – We recommend the following: • FFR Controls over Reporting Compliance: We recommend DBH strengthen its internal control to ensure timely review and approval of the FFR before report submission. • PPR Reporting Compliance: We recommend DBH develop formal, written procedures to identify the sources of information necessary and steps needed to compile accurate and complete information for the Opioid program performance reports; and retain in a central location all documentation that it used to support information included in each performance report it submits to the federal government. • SEFA Reporting Compliance: We recommend DBH ensure that agency personnel receive proper training on subrecipient versus vendor determination; as well as review existing policies and procedures for preparing the Schedule of Expenditures of Federal Awards to ensure that it is complete and accurate. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – The DBH Office of the Chief Financial Officer (OCFO) concurs with this finding. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.
2024-002 [2022‐002]—PREPARATION OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDSFederal Agency: All presented in the Schedule of Expenditures of Federal Awards. Program Name: All presented in the Schedule of Expenditures of Federal Awards. Assistance Listing Nos. and Program Expenditures: All presented in Schedule of Expenditures of Federal Awards. Award Number and Program Award Year: All awards presented in Schedule of Expenditures of Federal Awards. Compliance Requirement: Other – Schedule of Expenditures of Federal Awards preparation Type of Finding: (F) Significant Deficiency in Internal Control over Compliance of Federal Awards. Questioned Costs: None Statement of Condition During our audit, we reviewed the Coalition’s federal-grants report for the fiscal year and identified the grants, Assistance-Listing numbers (AL #s), expenditure amounts, and all other items required to properly present the Schedule of Expenditures of Federal Awards (SEFA). Finance staff subsequently confirmed the SEFA; however, additional federal expenditures and mis-grouped grant costs were found during later reviews. Criteria2 CFR 200.510 indicates that 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 2 CFR 200.502, Basis for Determining Federal Awards Expended. Per 2 CFR 200.502, the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards, such as expenditure/expense transactions associated with awards. In addition, 2 CFR Part 200.303 requires the program to establish and maintain effective internal controls over federal awards that provides reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of federal awards. Effect Without an established process governed by effective internal controls, the Coalition may not prevent or detect material misstatements on its SEFA in a timely manner. In addition, errors in SEFA preparation could affect the major federal program determination and lead to noncompliance with 2 CFR 200 Subpart F, which in turn could result in a substandard single audit. Cause Historically, the Coalition has requested the auditor assist in identifying accruals related to federal grant expenditures as the organization has maintained these records on a cash basis. As the organization has taken more responsibility on maintaining its federal grant expenditures on an accrual basis, an incomplete SEFA has been provided. Recommendation We recommend the Coalition prepare the Schedule of Expenditures of Federal Awards and submit this to the auditor for testing. The SEFA should include the name of the grant, name of grantor, the AL #, the pass-through number if applicable and a reconciliation of the federal revenues and expenditures to the Coalition’s general ledger. The Coalition staff should perform more detailed reviews of the reports to ensure they properly reflect grant receipts and expenditures. This review should be performed by someone other than the preparer and should include documented evidence of agreeing the reported data to the accounting records. We further recommend training for those individuals involved in the preparation and review of the reports to ensure they are fully aware of the requirements. View of Responsible Officials and Corrective Action Plan: The corrective Action Plan will be carried out in the 2025 Fiscal Year and information will be given to the auditors when requested for the next audit. The Coalition will ensure that all information needed for the SEFA is kept and entered accurately (this process has already begun). When the fiscal year closes out, the Coalition will provide the auditors with a test SEFA to confirm that the information we are collecting throughout the year and are asserting are the correct numbers for our federal grants, is indeed the correct information. Corrective Action Plan Timeline: Completed by December 19, 2025 (Final copy of the SEFA will not be given to the auditors until requested for the Audit).Designation Of Employee Position Responsible For Meeting Deadline: Executive Director will oversee this project and work directly with NMCEH finance staff work closely with the auditors to make sure that the information saved and shared is correct.
2024-002 [2022‐002]—PREPARATION OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDSFederal Agency: All presented in the Schedule of Expenditures of Federal Awards. Program Name: All presented in the Schedule of Expenditures of Federal Awards. Assistance Listing Nos. and Program Expenditures: All presented in Schedule of Expenditures of Federal Awards. Award Number and Program Award Year: All awards presented in Schedule of Expenditures of Federal Awards. Compliance Requirement: Other – Schedule of Expenditures of Federal Awards preparation Type of Finding: (F) Significant Deficiency in Internal Control over Compliance of Federal Awards. Questioned Costs: None Statement of Condition During our audit, we reviewed the Coalition’s federal-grants report for the fiscal year and identified the grants, Assistance-Listing numbers (AL #s), expenditure amounts, and all other items required to properly present the Schedule of Expenditures of Federal Awards (SEFA). Finance staff subsequently confirmed the SEFA; however, additional federal expenditures and mis-grouped grant costs were found during later reviews. Criteria2 CFR 200.510 indicates that 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 2 CFR 200.502, Basis for Determining Federal Awards Expended. Per 2 CFR 200.502, the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards, such as expenditure/expense transactions associated with awards. In addition, 2 CFR Part 200.303 requires the program to establish and maintain effective internal controls over federal awards that provides reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of federal awards. Effect Without an established process governed by effective internal controls, the Coalition may not prevent or detect material misstatements on its SEFA in a timely manner. In addition, errors in SEFA preparation could affect the major federal program determination and lead to noncompliance with 2 CFR 200 Subpart F, which in turn could result in a substandard single audit. Cause Historically, the Coalition has requested the auditor assist in identifying accruals related to federal grant expenditures as the organization has maintained these records on a cash basis. As the organization has taken more responsibility on maintaining its federal grant expenditures on an accrual basis, an incomplete SEFA has been provided. Recommendation We recommend the Coalition prepare the Schedule of Expenditures of Federal Awards and submit this to the auditor for testing. The SEFA should include the name of the grant, name of grantor, the AL #, the pass-through number if applicable and a reconciliation of the federal revenues and expenditures to the Coalition’s general ledger. The Coalition staff should perform more detailed reviews of the reports to ensure they properly reflect grant receipts and expenditures. This review should be performed by someone other than the preparer and should include documented evidence of agreeing the reported data to the accounting records. We further recommend training for those individuals involved in the preparation and review of the reports to ensure they are fully aware of the requirements. View of Responsible Officials and Corrective Action Plan: The corrective Action Plan will be carried out in the 2025 Fiscal Year and information will be given to the auditors when requested for the next audit. The Coalition will ensure that all information needed for the SEFA is kept and entered accurately (this process has already begun). When the fiscal year closes out, the Coalition will provide the auditors with a test SEFA to confirm that the information we are collecting throughout the year and are asserting are the correct numbers for our federal grants, is indeed the correct information. Corrective Action Plan Timeline: Completed by December 19, 2025 (Final copy of the SEFA will not be given to the auditors until requested for the Audit).Designation Of Employee Position Responsible For Meeting Deadline: Executive Director will oversee this project and work directly with NMCEH finance staff work closely with the auditors to make sure that the information saved and shared is correct.
2024-002 [2022‐002]—PREPARATION OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDSFederal Agency: All presented in the Schedule of Expenditures of Federal Awards. Program Name: All presented in the Schedule of Expenditures of Federal Awards. Assistance Listing Nos. and Program Expenditures: All presented in Schedule of Expenditures of Federal Awards. Award Number and Program Award Year: All awards presented in Schedule of Expenditures of Federal Awards. Compliance Requirement: Other – Schedule of Expenditures of Federal Awards preparation Type of Finding: (F) Significant Deficiency in Internal Control over Compliance of Federal Awards. Questioned Costs: None Statement of Condition During our audit, we reviewed the Coalition’s federal-grants report for the fiscal year and identified the grants, Assistance-Listing numbers (AL #s), expenditure amounts, and all other items required to properly present the Schedule of Expenditures of Federal Awards (SEFA). Finance staff subsequently confirmed the SEFA; however, additional federal expenditures and mis-grouped grant costs were found during later reviews. Criteria2 CFR 200.510 indicates that 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 2 CFR 200.502, Basis for Determining Federal Awards Expended. Per 2 CFR 200.502, the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards, such as expenditure/expense transactions associated with awards. In addition, 2 CFR Part 200.303 requires the program to establish and maintain effective internal controls over federal awards that provides reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of federal awards. Effect Without an established process governed by effective internal controls, the Coalition may not prevent or detect material misstatements on its SEFA in a timely manner. In addition, errors in SEFA preparation could affect the major federal program determination and lead to noncompliance with 2 CFR 200 Subpart F, which in turn could result in a substandard single audit. Cause Historically, the Coalition has requested the auditor assist in identifying accruals related to federal grant expenditures as the organization has maintained these records on a cash basis. As the organization has taken more responsibility on maintaining its federal grant expenditures on an accrual basis, an incomplete SEFA has been provided. Recommendation We recommend the Coalition prepare the Schedule of Expenditures of Federal Awards and submit this to the auditor for testing. The SEFA should include the name of the grant, name of grantor, the AL #, the pass-through number if applicable and a reconciliation of the federal revenues and expenditures to the Coalition’s general ledger. The Coalition staff should perform more detailed reviews of the reports to ensure they properly reflect grant receipts and expenditures. This review should be performed by someone other than the preparer and should include documented evidence of agreeing the reported data to the accounting records. We further recommend training for those individuals involved in the preparation and review of the reports to ensure they are fully aware of the requirements. View of Responsible Officials and Corrective Action Plan: The corrective Action Plan will be carried out in the 2025 Fiscal Year and information will be given to the auditors when requested for the next audit. The Coalition will ensure that all information needed for the SEFA is kept and entered accurately (this process has already begun). When the fiscal year closes out, the Coalition will provide the auditors with a test SEFA to confirm that the information we are collecting throughout the year and are asserting are the correct numbers for our federal grants, is indeed the correct information. Corrective Action Plan Timeline: Completed by December 19, 2025 (Final copy of the SEFA will not be given to the auditors until requested for the Audit).Designation Of Employee Position Responsible For Meeting Deadline: Executive Director will oversee this project and work directly with NMCEH finance staff work closely with the auditors to make sure that the information saved and shared is correct.
2024-002 [2022‐002]—PREPARATION OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDSFederal Agency: All presented in the Schedule of Expenditures of Federal Awards. Program Name: All presented in the Schedule of Expenditures of Federal Awards. Assistance Listing Nos. and Program Expenditures: All presented in Schedule of Expenditures of Federal Awards. Award Number and Program Award Year: All awards presented in Schedule of Expenditures of Federal Awards. Compliance Requirement: Other – Schedule of Expenditures of Federal Awards preparation Type of Finding: (F) Significant Deficiency in Internal Control over Compliance of Federal Awards. Questioned Costs: None Statement of Condition During our audit, we reviewed the Coalition’s federal-grants report for the fiscal year and identified the grants, Assistance-Listing numbers (AL #s), expenditure amounts, and all other items required to properly present the Schedule of Expenditures of Federal Awards (SEFA). Finance staff subsequently confirmed the SEFA; however, additional federal expenditures and mis-grouped grant costs were found during later reviews. Criteria2 CFR 200.510 indicates that 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 2 CFR 200.502, Basis for Determining Federal Awards Expended. Per 2 CFR 200.502, the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards, such as expenditure/expense transactions associated with awards. In addition, 2 CFR Part 200.303 requires the program to establish and maintain effective internal controls over federal awards that provides reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of federal awards. Effect Without an established process governed by effective internal controls, the Coalition may not prevent or detect material misstatements on its SEFA in a timely manner. In addition, errors in SEFA preparation could affect the major federal program determination and lead to noncompliance with 2 CFR 200 Subpart F, which in turn could result in a substandard single audit. Cause Historically, the Coalition has requested the auditor assist in identifying accruals related to federal grant expenditures as the organization has maintained these records on a cash basis. As the organization has taken more responsibility on maintaining its federal grant expenditures on an accrual basis, an incomplete SEFA has been provided. Recommendation We recommend the Coalition prepare the Schedule of Expenditures of Federal Awards and submit this to the auditor for testing. The SEFA should include the name of the grant, name of grantor, the AL #, the pass-through number if applicable and a reconciliation of the federal revenues and expenditures to the Coalition’s general ledger. The Coalition staff should perform more detailed reviews of the reports to ensure they properly reflect grant receipts and expenditures. This review should be performed by someone other than the preparer and should include documented evidence of agreeing the reported data to the accounting records. We further recommend training for those individuals involved in the preparation and review of the reports to ensure they are fully aware of the requirements. View of Responsible Officials and Corrective Action Plan: The corrective Action Plan will be carried out in the 2025 Fiscal Year and information will be given to the auditors when requested for the next audit. The Coalition will ensure that all information needed for the SEFA is kept and entered accurately (this process has already begun). When the fiscal year closes out, the Coalition will provide the auditors with a test SEFA to confirm that the information we are collecting throughout the year and are asserting are the correct numbers for our federal grants, is indeed the correct information. Corrective Action Plan Timeline: Completed by December 19, 2025 (Final copy of the SEFA will not be given to the auditors until requested for the Audit).Designation Of Employee Position Responsible For Meeting Deadline: Executive Director will oversee this project and work directly with NMCEH finance staff work closely with the auditors to make sure that the information saved and shared is correct.
2024-002 [2022‐002]—PREPARATION OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDSFederal Agency: All presented in the Schedule of Expenditures of Federal Awards. Program Name: All presented in the Schedule of Expenditures of Federal Awards. Assistance Listing Nos. and Program Expenditures: All presented in Schedule of Expenditures of Federal Awards. Award Number and Program Award Year: All awards presented in Schedule of Expenditures of Federal Awards. Compliance Requirement: Other – Schedule of Expenditures of Federal Awards preparation Type of Finding: (F) Significant Deficiency in Internal Control over Compliance of Federal Awards. Questioned Costs: None Statement of Condition During our audit, we reviewed the Coalition’s federal-grants report for the fiscal year and identified the grants, Assistance-Listing numbers (AL #s), expenditure amounts, and all other items required to properly present the Schedule of Expenditures of Federal Awards (SEFA). Finance staff subsequently confirmed the SEFA; however, additional federal expenditures and mis-grouped grant costs were found during later reviews. Criteria2 CFR 200.510 indicates that 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 2 CFR 200.502, Basis for Determining Federal Awards Expended. Per 2 CFR 200.502, the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards, such as expenditure/expense transactions associated with awards. In addition, 2 CFR Part 200.303 requires the program to establish and maintain effective internal controls over federal awards that provides reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of federal awards. Effect Without an established process governed by effective internal controls, the Coalition may not prevent or detect material misstatements on its SEFA in a timely manner. In addition, errors in SEFA preparation could affect the major federal program determination and lead to noncompliance with 2 CFR 200 Subpart F, which in turn could result in a substandard single audit. Cause Historically, the Coalition has requested the auditor assist in identifying accruals related to federal grant expenditures as the organization has maintained these records on a cash basis. As the organization has taken more responsibility on maintaining its federal grant expenditures on an accrual basis, an incomplete SEFA has been provided. Recommendation We recommend the Coalition prepare the Schedule of Expenditures of Federal Awards and submit this to the auditor for testing. The SEFA should include the name of the grant, name of grantor, the AL #, the pass-through number if applicable and a reconciliation of the federal revenues and expenditures to the Coalition’s general ledger. The Coalition staff should perform more detailed reviews of the reports to ensure they properly reflect grant receipts and expenditures. This review should be performed by someone other than the preparer and should include documented evidence of agreeing the reported data to the accounting records. We further recommend training for those individuals involved in the preparation and review of the reports to ensure they are fully aware of the requirements. View of Responsible Officials and Corrective Action Plan: The corrective Action Plan will be carried out in the 2025 Fiscal Year and information will be given to the auditors when requested for the next audit. The Coalition will ensure that all information needed for the SEFA is kept and entered accurately (this process has already begun). When the fiscal year closes out, the Coalition will provide the auditors with a test SEFA to confirm that the information we are collecting throughout the year and are asserting are the correct numbers for our federal grants, is indeed the correct information. Corrective Action Plan Timeline: Completed by December 19, 2025 (Final copy of the SEFA will not be given to the auditors until requested for the Audit).Designation Of Employee Position Responsible For Meeting Deadline: Executive Director will oversee this project and work directly with NMCEH finance staff work closely with the auditors to make sure that the information saved and shared is correct.
2024-002 [2022‐002]—PREPARATION OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDSFederal Agency: All presented in the Schedule of Expenditures of Federal Awards. Program Name: All presented in the Schedule of Expenditures of Federal Awards. Assistance Listing Nos. and Program Expenditures: All presented in Schedule of Expenditures of Federal Awards. Award Number and Program Award Year: All awards presented in Schedule of Expenditures of Federal Awards. Compliance Requirement: Other – Schedule of Expenditures of Federal Awards preparation Type of Finding: (F) Significant Deficiency in Internal Control over Compliance of Federal Awards. Questioned Costs: None Statement of Condition During our audit, we reviewed the Coalition’s federal-grants report for the fiscal year and identified the grants, Assistance-Listing numbers (AL #s), expenditure amounts, and all other items required to properly present the Schedule of Expenditures of Federal Awards (SEFA). Finance staff subsequently confirmed the SEFA; however, additional federal expenditures and mis-grouped grant costs were found during later reviews. Criteria2 CFR 200.510 indicates that 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 2 CFR 200.502, Basis for Determining Federal Awards Expended. Per 2 CFR 200.502, the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards, such as expenditure/expense transactions associated with awards. In addition, 2 CFR Part 200.303 requires the program to establish and maintain effective internal controls over federal awards that provides reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of federal awards. Effect Without an established process governed by effective internal controls, the Coalition may not prevent or detect material misstatements on its SEFA in a timely manner. In addition, errors in SEFA preparation could affect the major federal program determination and lead to noncompliance with 2 CFR 200 Subpart F, which in turn could result in a substandard single audit. Cause Historically, the Coalition has requested the auditor assist in identifying accruals related to federal grant expenditures as the organization has maintained these records on a cash basis. As the organization has taken more responsibility on maintaining its federal grant expenditures on an accrual basis, an incomplete SEFA has been provided. Recommendation We recommend the Coalition prepare the Schedule of Expenditures of Federal Awards and submit this to the auditor for testing. The SEFA should include the name of the grant, name of grantor, the AL #, the pass-through number if applicable and a reconciliation of the federal revenues and expenditures to the Coalition’s general ledger. The Coalition staff should perform more detailed reviews of the reports to ensure they properly reflect grant receipts and expenditures. This review should be performed by someone other than the preparer and should include documented evidence of agreeing the reported data to the accounting records. We further recommend training for those individuals involved in the preparation and review of the reports to ensure they are fully aware of the requirements. View of Responsible Officials and Corrective Action Plan: The corrective Action Plan will be carried out in the 2025 Fiscal Year and information will be given to the auditors when requested for the next audit. The Coalition will ensure that all information needed for the SEFA is kept and entered accurately (this process has already begun). When the fiscal year closes out, the Coalition will provide the auditors with a test SEFA to confirm that the information we are collecting throughout the year and are asserting are the correct numbers for our federal grants, is indeed the correct information. Corrective Action Plan Timeline: Completed by December 19, 2025 (Final copy of the SEFA will not be given to the auditors until requested for the Audit).Designation Of Employee Position Responsible For Meeting Deadline: Executive Director will oversee this project and work directly with NMCEH finance staff work closely with the auditors to make sure that the information saved and shared is correct.
2024-002 [2022‐002]—PREPARATION OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDSFederal Agency: All presented in the Schedule of Expenditures of Federal Awards. Program Name: All presented in the Schedule of Expenditures of Federal Awards. Assistance Listing Nos. and Program Expenditures: All presented in Schedule of Expenditures of Federal Awards. Award Number and Program Award Year: All awards presented in Schedule of Expenditures of Federal Awards. Compliance Requirement: Other – Schedule of Expenditures of Federal Awards preparation Type of Finding: (F) Significant Deficiency in Internal Control over Compliance of Federal Awards. Questioned Costs: None Statement of Condition During our audit, we reviewed the Coalition’s federal-grants report for the fiscal year and identified the grants, Assistance-Listing numbers (AL #s), expenditure amounts, and all other items required to properly present the Schedule of Expenditures of Federal Awards (SEFA). Finance staff subsequently confirmed the SEFA; however, additional federal expenditures and mis-grouped grant costs were found during later reviews. Criteria2 CFR 200.510 indicates that 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 2 CFR 200.502, Basis for Determining Federal Awards Expended. Per 2 CFR 200.502, the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards, such as expenditure/expense transactions associated with awards. In addition, 2 CFR Part 200.303 requires the program to establish and maintain effective internal controls over federal awards that provides reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of federal awards. Effect Without an established process governed by effective internal controls, the Coalition may not prevent or detect material misstatements on its SEFA in a timely manner. In addition, errors in SEFA preparation could affect the major federal program determination and lead to noncompliance with 2 CFR 200 Subpart F, which in turn could result in a substandard single audit. Cause Historically, the Coalition has requested the auditor assist in identifying accruals related to federal grant expenditures as the organization has maintained these records on a cash basis. As the organization has taken more responsibility on maintaining its federal grant expenditures on an accrual basis, an incomplete SEFA has been provided. Recommendation We recommend the Coalition prepare the Schedule of Expenditures of Federal Awards and submit this to the auditor for testing. The SEFA should include the name of the grant, name of grantor, the AL #, the pass-through number if applicable and a reconciliation of the federal revenues and expenditures to the Coalition’s general ledger. The Coalition staff should perform more detailed reviews of the reports to ensure they properly reflect grant receipts and expenditures. This review should be performed by someone other than the preparer and should include documented evidence of agreeing the reported data to the accounting records. We further recommend training for those individuals involved in the preparation and review of the reports to ensure they are fully aware of the requirements. View of Responsible Officials and Corrective Action Plan: The corrective Action Plan will be carried out in the 2025 Fiscal Year and information will be given to the auditors when requested for the next audit. The Coalition will ensure that all information needed for the SEFA is kept and entered accurately (this process has already begun). When the fiscal year closes out, the Coalition will provide the auditors with a test SEFA to confirm that the information we are collecting throughout the year and are asserting are the correct numbers for our federal grants, is indeed the correct information. Corrective Action Plan Timeline: Completed by December 19, 2025 (Final copy of the SEFA will not be given to the auditors until requested for the Audit).Designation Of Employee Position Responsible For Meeting Deadline: Executive Director will oversee this project and work directly with NMCEH finance staff work closely with the auditors to make sure that the information saved and shared is correct.
2024-002 [2022‐002]—PREPARATION OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDSFederal Agency: All presented in the Schedule of Expenditures of Federal Awards. Program Name: All presented in the Schedule of Expenditures of Federal Awards. Assistance Listing Nos. and Program Expenditures: All presented in Schedule of Expenditures of Federal Awards. Award Number and Program Award Year: All awards presented in Schedule of Expenditures of Federal Awards. Compliance Requirement: Other – Schedule of Expenditures of Federal Awards preparation Type of Finding: (F) Significant Deficiency in Internal Control over Compliance of Federal Awards. Questioned Costs: None Statement of Condition During our audit, we reviewed the Coalition’s federal-grants report for the fiscal year and identified the grants, Assistance-Listing numbers (AL #s), expenditure amounts, and all other items required to properly present the Schedule of Expenditures of Federal Awards (SEFA). Finance staff subsequently confirmed the SEFA; however, additional federal expenditures and mis-grouped grant costs were found during later reviews. Criteria2 CFR 200.510 indicates that 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 2 CFR 200.502, Basis for Determining Federal Awards Expended. Per 2 CFR 200.502, the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards, such as expenditure/expense transactions associated with awards. In addition, 2 CFR Part 200.303 requires the program to establish and maintain effective internal controls over federal awards that provides reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of federal awards. Effect Without an established process governed by effective internal controls, the Coalition may not prevent or detect material misstatements on its SEFA in a timely manner. In addition, errors in SEFA preparation could affect the major federal program determination and lead to noncompliance with 2 CFR 200 Subpart F, which in turn could result in a substandard single audit. Cause Historically, the Coalition has requested the auditor assist in identifying accruals related to federal grant expenditures as the organization has maintained these records on a cash basis. As the organization has taken more responsibility on maintaining its federal grant expenditures on an accrual basis, an incomplete SEFA has been provided. Recommendation We recommend the Coalition prepare the Schedule of Expenditures of Federal Awards and submit this to the auditor for testing. The SEFA should include the name of the grant, name of grantor, the AL #, the pass-through number if applicable and a reconciliation of the federal revenues and expenditures to the Coalition’s general ledger. The Coalition staff should perform more detailed reviews of the reports to ensure they properly reflect grant receipts and expenditures. This review should be performed by someone other than the preparer and should include documented evidence of agreeing the reported data to the accounting records. We further recommend training for those individuals involved in the preparation and review of the reports to ensure they are fully aware of the requirements. View of Responsible Officials and Corrective Action Plan: The corrective Action Plan will be carried out in the 2025 Fiscal Year and information will be given to the auditors when requested for the next audit. The Coalition will ensure that all information needed for the SEFA is kept and entered accurately (this process has already begun). When the fiscal year closes out, the Coalition will provide the auditors with a test SEFA to confirm that the information we are collecting throughout the year and are asserting are the correct numbers for our federal grants, is indeed the correct information. Corrective Action Plan Timeline: Completed by December 19, 2025 (Final copy of the SEFA will not be given to the auditors until requested for the Audit).Designation Of Employee Position Responsible For Meeting Deadline: Executive Director will oversee this project and work directly with NMCEH finance staff work closely with the auditors to make sure that the information saved and shared is correct.
2024-002 [2022‐002]—PREPARATION OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDSFederal Agency: All presented in the Schedule of Expenditures of Federal Awards. Program Name: All presented in the Schedule of Expenditures of Federal Awards. Assistance Listing Nos. and Program Expenditures: All presented in Schedule of Expenditures of Federal Awards. Award Number and Program Award Year: All awards presented in Schedule of Expenditures of Federal Awards. Compliance Requirement: Other – Schedule of Expenditures of Federal Awards preparation Type of Finding: (F) Significant Deficiency in Internal Control over Compliance of Federal Awards. Questioned Costs: None Statement of Condition During our audit, we reviewed the Coalition’s federal-grants report for the fiscal year and identified the grants, Assistance-Listing numbers (AL #s), expenditure amounts, and all other items required to properly present the Schedule of Expenditures of Federal Awards (SEFA). Finance staff subsequently confirmed the SEFA; however, additional federal expenditures and mis-grouped grant costs were found during later reviews. Criteria2 CFR 200.510 indicates that 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 2 CFR 200.502, Basis for Determining Federal Awards Expended. Per 2 CFR 200.502, the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards, such as expenditure/expense transactions associated with awards. In addition, 2 CFR Part 200.303 requires the program to establish and maintain effective internal controls over federal awards that provides reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of federal awards. Effect Without an established process governed by effective internal controls, the Coalition may not prevent or detect material misstatements on its SEFA in a timely manner. In addition, errors in SEFA preparation could affect the major federal program determination and lead to noncompliance with 2 CFR 200 Subpart F, which in turn could result in a substandard single audit. Cause Historically, the Coalition has requested the auditor assist in identifying accruals related to federal grant expenditures as the organization has maintained these records on a cash basis. As the organization has taken more responsibility on maintaining its federal grant expenditures on an accrual basis, an incomplete SEFA has been provided. Recommendation We recommend the Coalition prepare the Schedule of Expenditures of Federal Awards and submit this to the auditor for testing. The SEFA should include the name of the grant, name of grantor, the AL #, the pass-through number if applicable and a reconciliation of the federal revenues and expenditures to the Coalition’s general ledger. The Coalition staff should perform more detailed reviews of the reports to ensure they properly reflect grant receipts and expenditures. This review should be performed by someone other than the preparer and should include documented evidence of agreeing the reported data to the accounting records. We further recommend training for those individuals involved in the preparation and review of the reports to ensure they are fully aware of the requirements. View of Responsible Officials and Corrective Action Plan: The corrective Action Plan will be carried out in the 2025 Fiscal Year and information will be given to the auditors when requested for the next audit. The Coalition will ensure that all information needed for the SEFA is kept and entered accurately (this process has already begun). When the fiscal year closes out, the Coalition will provide the auditors with a test SEFA to confirm that the information we are collecting throughout the year and are asserting are the correct numbers for our federal grants, is indeed the correct information. Corrective Action Plan Timeline: Completed by December 19, 2025 (Final copy of the SEFA will not be given to the auditors until requested for the Audit).Designation Of Employee Position Responsible For Meeting Deadline: Executive Director will oversee this project and work directly with NMCEH finance staff work closely with the auditors to make sure that the information saved and shared is correct.